# docs_fts_content

c1: EFTA00029885
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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029885.pdf
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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re: Epstein accounts
Date: Thu, 06 Aug 2020 18:49:44 +0000
This is odd - the guy in USVI sent me a seemingly very different email yesterday. Will forward.
Sent from my iPhone
On Aug 6, 2020, at 2:31 PM,
)
wrote:
Refreshing this - please let us know? Or happy to discuss if necessary. Thanks.
On Aug 3, 2020, at 18:56,
)
wrote:
FYI, below - the AG's office at USVI is basically just trying to copy our investigation. Do we care if DB provides our
subpoenas, what they produced to us, to USVI AG?
From: Moyne, Parvin
Sent: Monday, August 03, 2020 12:12
To:
Cc: DiPiero, Joseph
Moyer, Thomas
is
Subject: RE: Epstein accounts
I hope you are well and getting some time "off" this summer. I'm reaching out via email as it may be the most efficient
way to tee-up the inquiry we have received, but we can circulate a dial-in at a convenient time for you if you'd like to
discuss anything.
Deutsche Bank has received a third-party subpoena from the Attorney General's Office of the U.S. Virgin Islands in
connection with a pending civil suit they have filed against Jeffrey Epstein's estate, the executors of the estate, and
others. One of the requests is for a copy of any government subpoenas received by the Bank relating to Epstein, and a
copy of any productions made pursuant to the subpoenas. Do we have your permission to disclose your subpoena and
our production to you to the U.S.V.I. AG? Would you prefer us to refer the office to you directly or provide you with
contact information? I'm happy to send you a copy of the U.S.V.I. AG subpoena if helpful in evaluating the request.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
Direct:
Internal:
EFTA00029885

=== Page 2 ===
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EFTA00029886


c1: EFTA00031410
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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031410.pdf
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=== Page 1 ===
From:
To:
Subject: Delayed Disclosure Ltr in Tartaglione
Date: Wed, 05 Aug 2020 21:48:03 +0000
Attachments: 2020.08.XX_letter_to_KMK_re_Penalty_Phase_Brady_v1.docx
I
Draft letter attached along the lines we discussed. After I get your comments l'll begin the discussion
with McEnany.
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York New York 10007
EFTA00031410


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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030985.pdf
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=== Page 1 ===
From:
To:
Cc:
Subject: PCU Monthly Updates
Date: Fri, 07 May 2021 15:05:20 +0000
Attachments: PC_Unit_-_Short_Form_Update.5.7.21.docx --
See attached.
Chief, Public Corruption Unit
U.S. Attorney's Offfice for the
Southern District of New York
EFTA00030985


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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030631.pdf
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=== Page 1 ===
From:
Subject: 2021.10.28 order re November 1 Conference.pdf
Date: Mon, 01 Nov 2021 13:50:41 +0000
Attachments: 2021.10.28_order_re_November_1_Conference.pdf
Here's the order for the conference with courtrooms/overflow rooms.
EFTA00030631


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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Date: Mon, 28 Dec 2020 21:56:48 +0000
Embedded: RE:_Activity_in_Case_1:20-cr-00330-AJN_USA_v_Maxwell_Ordermsg
Sender:
Subject: RE: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Message-Id:
<SN5P110MB054282C2C4831EE1BD41501792D90@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
EFTA00031707


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: Re: laptop for MDC
Date: Mon, 02 Nov 2020 17:19:57 +0000
Hi
Hope you're doing well. Has the laptop arrived? The warden has approved our request to give the defendant this
laptop, and we would like to have it ready by the end of the week if at all possible. If you have any questions, I
can be reached at
anytime today. Thanks so much for your help with this project.
Best,
Sent from my iPhone
On Oct 28, 2020, at 2:44 PM,
(USANYS)
wrote:
It sure we will research one tonight and place the order tomorrow. It depends on availability and delivery. Do
we have a copy of the data that goes with the drive?
Also with the ever changing policies in BOP, can you confirm that they will allow her to have a laptop. Not
sure the rules at MDC.
Sent from my iPhone
On Oct 28, 2020, at 2:22 PM,
)
wrote:
Perfect, thanks so much. How long would you estimate that will take?
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:20 PM
To:
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
We will spec out a laptop to purchase for this case.
From:
Sent: Wednesday, October 28, 2020 2:09 PM
To:
(USANYS)
Cc:
)
is
(USANYS)
Subject: RE: laptop for MDC
Thanks so much.
EFTA00030526

=== Page 2 ===
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:06 PM
To:
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
Let me discuss with Ed the best options. get back to you shortly.
From:
Sent: Wednesday, October 28, 2020 1:58 PM
To:
(USANYS)
Cc:
)
is
(USANYS)
Subject: laptop for MDC
Hi
I hope you're doing well. Because of some discovery accessibility issues we're having in the Ghislaine Maxwell case, we
would like to provide a clean laptop to Maxwell in MDC for discovery review purposes. The laptop need only permit
review of standard files - word, pdf, .tif, .xls, etc. All other capabilities and programs can be disabled. I understand we
did something similar in the Avenatti case, and
like to do the same here. Would that be possible? It would be a
huge help to us if you could possibly prep and provide us with a laptop for this purpose.
Thanks so much-
EFTA00030527


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=== Page 1 ===
From: New York Law360 <news-alt@law360.com>
To:
Subject: Possible Child Porn May Undo Epstein Bid For Home Jail
Date: Mon, 15 Jul 2019 08:24:51 +0000
Law360 New York
NEW YORK
Monday, July 15, 2019
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
Analysis
Possible Child Porn May Undo Epstein Bid For Home Jail
Wealthy financier Jeffrey Epstein's bid for release ahead of trial on underage
sex trafficking charges may be a hard sell given the wishes of victims and
what could be child pornography found in his home, despite his offer to pay
private guards to keep watch.
Read full article
Feds Say Epstein Paid Potential Witnesses; More Victims ID'd
Financier and convicted sex offender Jeffrey Epstein paid $350,000 in a
possible attempt to influence two potential witnesses in his sex trafficking
case, New York federal prosecutors said Friday, adding that more women
Listen to our new podcast here
alleging they were Epstein's victims have come forward.
Letter attached Read full article
LAW FIRMS
Alioto Law Firm
SunEdison Settles With Investors For $74M
Arnold & Porter
SunEdison Inc. investors inked a $74 million cash deal to end their class
action suit accusing the renewable energy company of maintaining faulty
Beck Reed
internal controls and filing inaccurate financial statements, they told a New
Bernstein Litowitz
York federal judge Friday.
Blank Rome
1 document attached Read full article
Boies Schiller
Booth Udall
Thorny Issues In Orioles-Nationals Arbitration Trouble Judge
Briggs and Morgan
A New York state trial court judge on Friday said he was "genuinely
Buchanan Ingersoll
struggling" with legal questions raised by claims from the Baltimore Orioles
and Mid-Atlantic Sports Network that an arbitration award against them is so
Clayman & Rosenberg
unfair that the courts should intervene.
Cleary Gottlieb
Read full article
Consovoy McCarthy
Covington & Burling
POLICY & REGULATION
DLA Piper
DC Circ. Questions Trump Fight To Defy Financial Subpoenas
Faegre Baker
Fenwick & West
Two D.C. Circuit judges seemed highly skeptical of President Donald Trump's
arguments Friday that his personal financial and hotel business records are
Gadow Tyler
off limits to Congress, though a third judge asked House Democrats' legal
Gibson Dunn
team to better justify their demands for the documents.
Gordon & Rees
Read full article
HeplerBroom LLC
PRODUCT LIABILITY
Husch Blackwell
Immigration Law PLLC
Kaplan Fox
EFTA00030281

=== Page 2 ===
18 State AGs Call On House To Ban Asbestos
Kellogg Hansen
A group of 18 attorneys general on Friday urged the House's Committee on
Kessler Topaz
Energy and Commerce to enact a full ban on making, importing and
Kirkland & Ellis
distributing asbestos within the U.S.
Latham & Watkins
Letter attached Read full article
Levi & Korsinsky
Locke Lord
CONSUMER PROTECTION
Michael Best
L'Oreal Dodges Claims Over Misleading Cosmetics Bottles
Milbank LLP
A New York federal judge has dismissed a suit alleging that L'Oreal USA
Modus Law
Inc.'s cosmetics labels mislead customers, saying reasonable customers
Morgan Lewis
would not expect to get all of a viscous fluid out of the bottle with the pumps
Morrison & Foerster
used in L'Oreal's products.
Patterson Belknap
Order attached Read full article
Paul Hastings
INTELLECTUAL PROPERTY
Paul Weiss
Peabody & Arnold
Signet: Investor Cert. Needs Clarification. Judge: WRONG
Quinn Emanuel
A New York federal judge refused Thursday to clarify an order certifying a
Schoeppl Law
class of investors suing over Signet's alleged culture of sexual harassment,
Sher Tremonte
calling the retailer's interpretation "completely, totally and utterly WRONG"
Shook Hardy
and setting the stage for an appeal.
1 document attached Read full article
Sidley Austin
Silver Miller
Prominent Union Leader Dies Of Heart Attack At 57
Simpson Thacher
Prominent labor leader Héctor Figueroa, president of the New York-based
Skadden
property service workers' union 32BJ SEIU, has died of a heart attack, the
Snyder Law Firm LLC (Leawood,
union announced Friday.
KS)
Read full article
Steptoe & Johnson LLP
Sullivan & Cromwell
SECURITIES & WHITE COLLAR
Thompson Coburn
Investor Who Filed $4B Crypto Ponzi Suit Cut From Lead
Troutman Sanders
A New York federal judge has denied two investors' bid to jointly lead a $4
Wachtell Lipton
billion lawsuit over an alleged cryptocurrency Ponzi scheme, handing the
Weil Gotshal
lead to the investor claiming greater losses rather than the one who filed the
WeissLaw LLP
suit, saying the "unrelated" pair won't "function cohesively."
White and Williams
1 document attached Read full article
Williams Dirks Dameron
WilmerHale
Ex-NBA Star Should Do Time For Taking Bribes, Gov't Says
Zuckerman Spaeder
Federal prosecutors took a dim view Friday of Chuck Connors Person's
request for leniency in a Manhattan bribery case, rejecting the former NBA
COMPANIES
rookie of the year's assertion that he was in dire financial straits and pointing
out that he was on the take while earning $250,000 a year coaching at
32BJ SEIU
Auburn University.
ACNB Corporation
2 documents attached Read full article »
Acacia Communications Inc.
Amazon.com Inc.
SEC Accuses 'Experienced' Securities Atty Of Trading Scheme
American Bar Association
The U.S. Securities and Exchange Commission is accusing an "experienced
American Civil Liberties Union
securities lawyer" of carrying out a multimillion-dollar scheme to sell
unregistered penny stock shares, according to a case filed Friday in New
American Immigration Lawyers
Association
York federal court.
BAC Florida Bank
Complaint attached
Read full article
Baltimore Orioles
CEO Accused Of Draining $3M From NJ Terra Cotta Co.
Banco Bradesco SA
A New Jersey-based terra cotta facade business' minority shareholder sued
Bank of America Corp.
the company's president and CEO in New York federal court Friday, accusing
Barclays PLC
EFTA00030282

=== Page 3 ===
the executive of misusing company funds and draining at least $3 million
Benco Dental Supply Co. Inc.
from his company.
Caterpillar Inc.
Complaint attached
Read full article
Cisco Systems Inc.
BANKING
Citigroup Inc.
Conn's Inc.
DOJ Granted Deposition Delay In Forex-Rigging Suit
Electronic Privacy Information
A New York federal judge overseeing a foreign exchange market rigging suit
Center
against several big banks is allowing the U.S. Department of Justice to delay
deposition for three months, defying protests from investors who argue that
Ernst & Young
the agency has been seeking extension requests to stall prosecution of their
Federal Bar Association
case.
Financial Industry Regulatory
Letter attached Read full article
Authority Inc.
General Cable Corp.
Bank Of America, Morgan Stanley Again Accused Of Spoofing
Goldman Sachs Group Inc.
Morgan Stanley & Co. LLC, Bank of America Corp. and its subsidiary Merrill
Google Inc.
Lynch Commodities Inc. engaged in spoofing in an effort to manipulate
HSBC Holdings PLC
precious metals futures, according to a proposed class action filed Friday in
New York federal court.
Hearst Corp.
Complaint attached Read full article
Henry Schein Inc.
Indiana Pacers
Attys Get $4.9M In Fees In Citigroup Exchange Rate Suit
JPMorgan Chase & Co.
The attorneys for a class of Citigroup Inc.-sponsored American depositary
L'Oreal SA
receipt holders will receive nearly $5 million in fees after securing a $14.75
LexisNexis Group
million settlement in a suit alleging the bank manipulated the foreign
exchange rate when providing dividends to ADR holders.
Major League Baseball Inc.
1 document attached Read full article
Major Lindsey & Africa
Mazars USA LLP
COMPETITION
Morgan Stanley
National Conference of State
Dental Supplier Says 2nd Circ. Sunk Startup's Damages Claim
Legislatures
Benco Dental Supply Co. told a New York federal court on Thursday that a
New York Times Co.
recent ruling from the Second Circuit shows that the damages being pursued
Nokia Corporation
by online supplier SourceOne Dental Inc. over an alleged boycott are too
North American Securities
speculative.
Administrators Association
2 documents attached Read full article
Palladium Equity Partners LLC
Patterson Companies Inc.
TAX
Paypal Holdings Inc.
Atty Eyed In E&Y Tax Shelter Case Jailed After Extradition
Piper Jaffray Companies
A lawyer charged in 2008 with helping former Ernst & Young LLP partners
Platinum Partners LP
develop fraudulent tax shelters for high-end clients and failing to report at
RELX PLC
least $8 million of tax liability was jailed Friday by a Manhattan federal judge
Rexford Industrial Realty Inc.
after being extradited to the U.S. from Canada.
Rockland Trust Co.
Read full article
SIFMA
Taxation With Representation: Skadden, Sullivan, Wachtell
Sandler O'Neill & Partners LP
In this week's Taxation With Representation, Piper Jaffray and Sandler
Signet Jewelers Ltd.
O'Neill join forces in a $485 million merger, Cisco snaps up fiber optics
Spectrum Management Holding
company Acacia Communications for $2.6 billion, and Virgin Galactic merges
Co.
with a special purpose acquisition company held by Social Capital and
Spotify Technology SA
Hedosophia to create a $1.5 billion company.
Sterling Jewelers Inc.
Read full article
SunEdison LLC
CAPITAL MARKETS
The Royal Bank of Scotland Group
PLC
Palladium Closes $1.6B Fund Targeting Middle Market Cos.
Trump Organization Inc.
Palladium Equity Partners said Friday it closed its latest fund with roughly
U.S. Chamber of Commerce
$1.6 billion in commitments that will be used to invest in and partner with
Washington Nationals
EFTA00030283

=== Page 4 ===
middle market companies.
Washington Post Co.
Read full article
REAL ESTATE & DEVELOPMENT
GOVERNMENT AGENCIES
Commodity Futures Trading
Real Estate Rumors: Carlton, Omega, Rockland Trust
Commission
Carlton Group is reportedly taking 6,000 square feet in Manhattan, Omega
European Banking Authority
Cinema Props is said to be leasing 245,000 square feet in Los Angeles, and
European Union
Rockland Trust has reportedly loaned $13.8 million for a Massachusetts
Executive Office for Immigration
affordable housing project.
Review
Read full article
Federal Bureau of Investigation
EXPERT ANALYSIS
Federal Trade Commission
lowa Attorney General's Office
Patchwork Of Broker Conduct Regs Complicates Compliance
New York Attorney General's Office
Until challenges to the U.S. Securities and Exchange Commission's newly
Securities and Exchange
adopted Regulation Best Interest play out in court, broker-dealers can
Commission
reconcile conflicting state and federal standards of conduct by complying with
Social Security Administration
the most restrictive applicable regulatory requirements, say Ghillaine Reid
U.S. Attorney's Office
and Kurt Wolfe of Troutman Sanders.
4 documents attached Read full article
U.S. Court of Appeals for the
District of Columbia Circuit
State Net
U.S. Department of Justice
Local Governments Push To Regulate Public Surveillance
U.S. District Court for the Eastern
San Francisco's Board of Supervisors recently approved an ordinance
District of New York
banning the use of facial recognition technology by all city departments. The
U.S. District Court for the Southern
law is part of a growing movement among localities and states to increase
District of New York
oversight of the use of surveillance technologies by government entities, says
U.S. Environmental Protection
Korey Clark of State Net Capitol Journal.
Agency
Read full article
U.S. House Committee on Energy
and Commerce
LEGAL INDUSTRY
U.S. Immigration and Customs
Enforcement
In Appalachia, A Lawyer's Vast Fraud Dogs Destitute Clients
U.S. Supreme Court
Four years have passed since an attorney's unprecedented fraud led to the
sudden suspension or reduction of disability benefits for thousands of people.
But despite a massive pro bono effort, many are still fighting to convince the
government they played no part in the scheme.
Read full article
Why Judge Christina Snyder Needs Her Coffee Strong
In a recent interview, U.S. District Court Senior Judge Christina Snyder spoke
with Law360 about her working weekends, collecting the art of Mary Corse
and the political women she'd like to have lunch with, but can't.
Read full article
Law Firm Leaders Expect Growth, But Also Rising Expenses
Law firm managers eyeing the remainder of 2019 have slightly higher
confidence in the U.S. and global economies, but expenses are expected to
eat into a greater chunk of firms' bottom lines, according to a survey released
Friday.
Read full article
Thompson Coburn Chair To Be Succeeded By Litigation Head
Thompson Coburn LLP on Friday announced that current Chair Tom Minogue
will leave the position next July, handing over the reins to Roman Wuller, who
currently heads the firm's litigation department.
Read full article
Feds Say Craig's Mueller Interview Relevant At FARA Trial
EFTA00030284

=== Page 5 ===
Federal prosecutors urged a D.C. judge on Thursday to allow evidence at the
upcoming trial of ex-Skadden partner Gregory Craig about how the firm was
paid for a controversial report at the center of the case and Craig's
statements about that report to special counsel Robert Mueller's investigators
last year.
Read full article
Legal Groups Call For Independent Immigration Courts
Four prominent legal organizations are urging lawmakers to grant the
immigration court system independence from the U.S. Department of Justice,
citing growing dysfunction and serious due process concerns within the
courts.
Read full article
GC Cheat Sheet: The Hottest Corporate News Of The Week
Observers think regulators are waiting to be convinced that broker-dealers
use effective processes to protect customer assets, and the Department of
Justice will now consider "robust" compliance programs when contemplating
bringing charges against whistleblower companies. These are some of the
stories in corporate legal news you may have missed in the past week.
Read full article
In Case You Missed It: Hottest Firms And Stories On Law360
For those who missed out, here's a look back at the law firms, stories and
expert analyses that generated the most buzz on Law360 last week.
Read full article
Podcast
Law360's Pro Say: Neal Katyal On Trump's Census About-Face
The Supreme Court term is over, but what will we remember 10 years from
now? On this week's Pro Say podcast, we're joined by former acting U.S.
Solicitor General Neal Katyal, who shares his take on the biggest trends,
Trump finally abandoning his plan to add a citizenship question to the
census, and whether stare decisis is in trouble.
Read full article
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EFTA00030285

=== Page 6 ===
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
Subject: Re: New Investigation
Date: Fri, 07 Dec 2018 01:33:52 +0000
Importance: Normal
Ok sounds good. I will be back from white plains hopefully by noon and will reach out.
Sent from my iPhone
> On Dec 6, 2018, at 6:21 PM,
)
wrote:
>
>
Same, can chat in person tomorrow and was a brief but good meeting with the agents.
V
>
>
Original Message
> From:
)
> Sent: Thursday, December 06, 2018 18:10
> To:
(USANYS)
> Cc:
)
>
Subject: RE: New Investigation
>
> No worries, happy to talk any time.
>
>
Original Message
> From:
(USANYS)
>
Sent: Thursday, December 6, 2018 6:04 PM
> To:
> Cc:
)
> Subject: Re: New Investigation
>
> Sorry I missed this. I am super annoyed. Just got out of mag court. Running home to feed the baby. But I am
around later tonight or tomorrow afternoon when I come back from white plains.
>
> Sent from my iPhone
V
On Dec 6, 2018, at 5:46 PM,
)
wrote:
>>
Thanks for taking the time to meet today-attached are the documents we mentioned.
From:
(NY) (FBI)
Sent: Thursday, December 6, 2018 1:40 PM
To:
)
>>
Cc:
)
(USANYS)
Subject: Re: New Investigation
>> I am still in NJ. I have everything we have downloaded to CD. It's at the office. I can bring it when we meet.
>>
EFTA00031366

=== Page 2 ===
Original message
From:
Date: 12/6/18 1:38 PM (GMT-05:00)
To:
)"
<mailto:
Cc:
)"
<mailto:
(USANYS)"
<mailto:
(NY) (FBI)"
Subject: Re: New Investigation
I'm in the proffer and do not have the disc with me. If I'm not mistaken
may still be in NJ. If I finish
up over here earlier then expected I'll ran back and grab it.
On Dec 6, 2018, at 12:59,
)
<mailto:
wrote:
>>
Hi all-looking forward to meeting this afternoon. If you're able to bring over a copy of the files on this case
(we'll take as much stuff as possible!), we'd really appreciate it. CD or drive are both fine.
Thanks!
From:
)
Sent: Tuesday, December 4, 2018 7:19 PM
To:
>>;
(USANYS)
(NY) (FBI)
Cc:
)
Subject: RE: New Investigation
No worries at all, and I'll make 4:30 work.
From:
Sent: Tuesday, December 04, 2018 19:16
To:
(USANYS)
(NY) (FBI)
>> Cc:
)
Subject: Re: New Investigation
>> I have child care issues in the mornings typically, and getting in by 11:00 is often difficult as I live in Suffolk
County. 4:30 works better for me. Sorry about that!
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
EFTA00031367

=== Page 3 ===
V
>>
From:
)
<mailto:
>>
Sent: Tuesday, December 4, 2018 7:06:28 PM
To:
,
(USANYS);
,
(NY) (FBI)
>> Cc:
)
Subject: RE: New Investigation
>> I unfortunately have calls at 4:00 and 4:30. Could we do earlier before 11:00? I'm also concerned that if the
proffer ends up going late we'll be out of luck. Or I can move the 4:30 if that's preferable for everybody. Sorry
about that.
From:
>>
Sent: Tuesday, December 04, 2018 19:04
To:
(USANYS)
(NY) (FBI)
>> Cc:
)
Subject: Re: New Investigation
>>
11:00 will not work for me. Me and
are good for 4:00 on Thursday though. The proffer should be
done by then.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
>> From:
)
EFTA00031368

=== Page 4 ===
<mailto:
>>
Sent: Tuesday, December 4, 2018 6:34:53 PM
To:
,
(USANYS);
,
(NY) (FBI)
Cc:
)
>>
Subject: RE: New Investigation
>> Let's do Thursday, particularly since schedules seem to be tough next week.
would it make sense to
,
meet before your proffer, so we can have a specified time? We could meet at 11:00.
thanks,
From:
>>
Sent: Tuesday, December 04, 2018 15:54
To:
(USANYS)
>;
,
(NY) (FBI)
>> Cc:
)
>>
Subject: Re: New Investigation
Hey guys,
Thursday I have a proffer at SNDY with SA
at 12:00. I can meet after that if you guys want
depending on how long this proffer goes. That may be the best option for us because Monday-Wednesday of next
week we may be tied up with a take down in the office.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
V
>>
From:
,
(USANYS)
<mailto:
EFTA00031369

=== Page 5 ===
>>
Sent: Tuesday, December 4, 2018 3:30:14 PM
To:
(NY) (FBI);
Cc:
);
)
Subject: RE: New Investigation
Thursday works for me.
Next week I am good Monday-Tuesday and Thursday-Friday.
From:
(NY) (FBI)
Sent: Tuesday, December 04, 2018 3:23 PM
To:
(USANYS)
(
>>
Cc:
Subject: RE: New Investigation
Hey
>> The only day I'd be free this week would be Thursday. Next Wednesday is not good, but any other day next
week I should be ok right now.
>>
I'm also working on putting everything we currently have onto a disk for you, so I should have that for you
when we meet.
From:
,
(USANYS) [mailto:
>>
Sent: Tuesday, December 04, 2018 2:14 PM
>> To:
(NY) (FBI)
>;
(NY)
(OGA)
>> Cc:
)
<mailto:
>;
<mailto:
>>
Subject: RE: New Investigation
>>
good speaking with you. I understand that you and
were just assigned the case yesterday and are
just starting to dig in. As we discussed I think it makes sense for us all to get into a room together son and chat.
EFTA00031370

=== Page 6 ===
>>
When works for you guys?
>>
>> From:
(USANYS)
>>
Sent: Monday, December 03, 2018 5:51 PM
>> To:
(NY) (FBI)
>;
(NY)
(OGA) (FBI)
>> Cc:
)
)
>>
Subject: New Investigation
>>
and
,
>>
>>
We got the package you dropped off today. Thank you. CC'ing the other members of the team on this email.
Best,
>>
>>
Assistant United States Attorney
>>
Human Trafficking Co-Coordinator
>>
>>
Violent & Organized Crime
Southern District of New York
>>
<Palm Beach Police Reports.pdf>
<Epstein Blackbook.pdf>
>>
<Flight Logs.pdf>
EFTA00031371


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=== Page 1 ===
From:
To:
)"
)"
Subject: Report on QAnon
Date: Thu, 01 Apr 2021 17:58:52 +0000
FYI, from the April DOJ Libraries Newsletter, "Countering QAnon: Understanding the
Role of Human Trafficking in the Disinformation-Extremist Nexus."
https://polarisproject.org/wp-content/uploads/2021/02/Polaris-Report-Countering
QAnon.pdf Epstein gets mentioned, starting at page nine.
This also mentions in passing that radicalized people search for QAnon merchandise to
buy on the internet. Seems to me that if that is so, that is a path to follow to people
doing this to make money. Not for you all, but perhaps for another Unit. Be well.
EFTA00030018


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Tue, 07 Jul 2020 18:27:02 +0000
Inline-Images: image001.png
This is now belated, but thank you!
From:
Sent: Friday, July 03, 2020 11:14
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
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 UNITED DONING SUBTOTAL
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
EFTA00031239

=== Page 2 ===
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
EFTA00031240

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
EFTA00031241

=== Page 4 ===
unless and until proven guilty.
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=== Page 1 ===
From:
To:
Subject: Issue discovery files
Date: Mon, 03 May 2021 18:44:45 +0000
Attachments: List_of_issue_disco_files_no_ranges.xlsx
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 Saint Andrew's Plaza
New York, NY 10007
EFTA00031689


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=== Page 1 ===
1. Priority
2. (-) if Arrest
SANTA MONICA POLICE DEPARTMENT
FLAG 1.3
3. DRI
CRIME REPORT
97-38046
4. Cossification
5. Location or Occurrance
SUMTIERS NOTEC
SEXUAL BATTERY
1 PICO BLVD.
SANTA MONICA Ch. 90401
& Date & Time Crime Occurred
7. Date A Time Rpts. to P.D.
c. Day of Wk. Occid.
9. Rpt. Dist. Occrd
05-12-97 1580-1700
05-20-97 1640
MONDAY
2D
10. Name
12. Res. Phone
13 Bus Phone
14. information Provided
15. Box. Address
Zip
TB. Occupation
Sex
Para
V-1
REPORTING PARTY
#11
MODEL
ACTROSS
Indicate with proper code in boxes provided, persons relation to investigation V-2 Vietim, W-1 withess, R/P reporting party, ofc.
VICTIM/WITNESS
/
17. WAS THERE A WITNESS TO THE CRIME?
IF NO PLACE AN X IN BOX
18. Name
Ren. Address
Zip
Res Phone
Bus. Phone
19. information Provided
But Address
Zip
Occupation
Sex Race Age
20. Name
Rdn. Address
Zip
Res. Phone
Bus. Phone
21. information Provided
Bus. Address
Zip
Occupation
Sex Race Age
22. WAS A SUSPECT ARRESTED?
IF NONE PLACE AN X IN BOX
23. CAN A SUSPECT BE NAMED?
IF NO PLACE AN x IN BOX
24. CAN A SUSPECT BE LOCATED?
IF NO PLACE AN X IN BOX
25. CAN A SUSPECT BE DESCRIBED?
IF NO PLACE AN X IN BOX
28.
Sex
Rece
Age
Height
Weight
Hair
Eyes
Compl
Cloining
S-1
38-
NAVY BLUE SWG TPANTS
SUSPECTS
M
w
56100
180
ALL
43
190
GRAY
BRN
MED.
WHITE T-SHIRT N/ as U.S.A LETERS IN RED
Name and Address Identifying marks and characteristics. of effected suspects full name, booking number and age only)
EPSTEIN, JEFFREY
BARE FOOT
27
Sex
Race
Age
Height
Weight
Har
Eyes
Compt
Clothing
5-2
Name and Accress. identifying marks and characteristics (If arrested suspects full name, booking number and age only.)
28. CAN A SUSPECT BE IDENTIFIED?
IF NO. PLACE AH X IN BOX
29. CAN THE SUSPECT VEHICLE BE IDENTIFIED?
IF NO PLACE AN X IN BOX
30. Suspect's vehicle Year. make, type, color, license number and any other identifying features
VEH.
LARGE 4-0000 MORCEDES BLACK
31 Victims Vent
32. WAS THERE A MAJOR INJURY OR RAPE VICTIM INVOLVED?
IF MD PLACE AN X IN BOX
INJ.
33 Where Hospitalized
34. EAP #
35. Date/Time
38. Attending Physician
37. Name of injury
38. IS THE STOLEN PROPERTY TRACEABLE?
IF NO PLACE AM X IN BOX
LOSS
39 Type of Property Taken
40. Location of Property N/A on Premises
41, Amount of LOBS
NONE
NONE
42. IS THERE A SIGNIFICANT M.O. PRESENT?
IF NO PLACE AN X IN BOX
43. Trademarks of Suspect(s) (Unusus Feature of Crime that is most apt to recur from crime to chme)
INTERVIEW
S.S POSING AS OR REPRESENTING VICTORIAS SECRET CO. GROPES R/P DURING
" Type of Premises
45. Method to Gain Entry
4d. Type of Weapon instrument or force
M.O.
HOTEL ROOM
HANDS
47. Were Documents Present
48. Premises Locise
49 Point of Entry
50. 17 Request
TAB
No.
Yes:
No
Yes
No
Serial # Items
inscribed herms
DO
ON 90
51. inv. Bur. or Units Notised & Persons Contacted
52. Pours of Exit
53.
Form #26 made
Form #38 made
8
Se. IS THERE SIGNIFICANT PHYSICAL EVIDENCE PRESENT?
IF NO PLACE AN X IN BOX
EVID.
55. HAS AN IDENTIFICATION TECHNICIAN BEEN INVOLVED?
IF NO PLACE AN X IN BOX
56. Evidence Taggwo? (Yes or No) 1 yes, Locker . or Person Released to
57. Property Report
NO
Yes
NO
97-38046
IS THERE A SIGNIFICANT REASON TO BELIEVE THAT CRIME MAY BE SOLVED?
IF NO PLACE AN X IN BOX
59 Reporting Officer Recommends
60. On Tape
61. Supervisor Rannaw
EZ. Inv. Bureau Screeting CSO
REVIEW
Office Rev. F/U
Yes
No
Concur.
O/R
Follow Up
Concur
O/R
Follow Up
63. Officer(s) Reporting
Senal No.
64. Supervisor Approving
Serial No.
65. Date & Time Signed
15-1
п EXHIBIT 30
Dershint
Deponent
Date 1/13/4 Rptr KT
WWW.DEPOBOOK.COM
EFTA00030257

=== Page 2 ===
2.3
Date & Time
Classification
05-20-97-1640
SEXUAL BATTERY
DR No. 97-38046
ON 05-20-97 AT 1640 HOURS I SPOKE WITH REPORTING
PARTY,
AT N.Q.
I REMEMBERED HAVING SPOKEN WITH
ORIGINALLY
ON 05-13-97 BRIEFLY AT APPROXIMATELY 1800 HOURS BEFORE
GOING OFF SHIFT
SAID THAT SHE HAD NOT FILED A REPORT ON
05-13-97 BUT WISHED TO so so NOW
SAID THAT ON 05-12-97 AT 1430 HOURS SHE
MET THE SUSPECT, JEFFERY EPSTEIN, AT SHUTTERS HOTEL
FOR A MODECINE INTERVISW
SAID THAT DURING THE INTERVIEW EPSTEIN TOLO
NER TO UNDRESS AND ACTUALLY ASSISTED HER TO DO so
WHILE SAYING, "LET ME MANHANDLE you FORA SECOND"
SAID EPSTEIN GROPED HER BUTTOCKS AGAINST
HER WILL WHILE ACTING AS THOUGH HE WAS EVALUATING HER
BODY,
SAID SHE INITIALLY MET EPSTEIN IN APRIL 97
THROUGH A MUTUAL FRIEND,
SAID
TOLD HER THAT SINCE SHE ISA MODEL
SHE SHOULD GIVE EPSTEIN A CALL TO GET SOME WORK
DA No.
WITH VICTORIA'S SECRET CATALOG
SAIO 3HE PHONED EPSTEIN AT FITHER HIS HOME
OR WORK (ii)
160
AND HE ASKED
NER TO SEND SOME PICTURES OF HERSELF,
97,085 Lb
Supervisor Approving
Serial No.
Officer Reporting
Serial No.
EFTA00030258

=== Page 3 ===
SANTA MONICA POLICE DEPARTMENT
CONTINUATION REPORT ( FIELD ) FORM SMPD 591
1. Booking Number
2. Page Number
3. DR Number
3-3
97-38046
ITEM
NO.
SAID SHE ARRINGED HER own PHOTO SESSION
AND MODELED VICTORIA'S SECRET BRIND LINGERIE in THE
PICTURES. SHE SAID SHE THEN FEDERAL EXPRESSED THEM
TO EPSTEIN AT 457 MADISON AVE. NY NY 10019
SAID EPSTEIN RECEIVED THE PHOTOS ON 05-09-97
AND PHONED HER, ASKING TO MEET HER, AND TOLD
HER THAT H/S SECRETARY WOULD CONTACT HER AND MAKE
AN APPOINTMENT
SAIO SHE RECEIVED THE CALL FROM KIMBERLY
ON 05-12-97 AT 0800 NOURS AND WAS GIVEN 1 CHOICE OF
TIMES TO MEST EPSTEN AT SHUTTERS; EITHER 1430 OR
1830 HOURS
SAID THAT SHE STARTED HAVING RESERVATIONS ABOUT
THE MEETING BECAUSE GENERALLY, INTERVIEWS Me E NOT
CONDUCTED IN HOTEL Rooms
SALO THAT ONCE INSIDE THE HOTEL Room WITH
EPSTEIN SHE WAS UNSURE OF WHETHER SHE was SAFE
BECAUSE ALTHOUGH SHE WANTED TO LAND THE JOB AS A
MODEL IN VICTORIAS SECRET CATALOG, SHE FELT AS
THOUGH EPSTEIN WAS ATTEMPTING TO GET HER TO ACT IN
AN LINPROFESSIONAL MANNER FOR MODEL
SAIO THAT AT ONE POINT EPSTEN ASKED HER
TO ANDRESS A SECOND TIME THE ACTUALLY ASSISTED NER BY
PULLING HER BLOUSE up AND PULLING HGR SKIRT up AND GROPWS
HER BUTTOCKS WIRE SAYING LETME MANHANDLE you FORA
SECOND."
TOTAL VALUE $
0 SERVICE APPROVISE
TOTAL *0.
15. REPORTING CRDW
EFTA00030259


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Mon, 10 Aug 2020 21:48:47 +0000
Good evening
Just confirming - did you use FedEx, USPS, or some other carrier to send the discovery here? I have not received it yet, but it
could just be that staff did not notify me a package arrived. Depending on the carrier, it could be in the warehouse or
mailroom, so I just want to verify so I can find it expeditiously.
Thanks!
8/5/2020 7:13 PM >>>
That's extremely helpful, thanks so much. We'll plan to put the drive in the mail tomorrow, and of course please let us
know if any issues arise.
thanks again,
From:
Sent: Wednesday, August 05, 2020 19:05
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password protected
so long as you include a cover letter that contains the password for her.
Hope this helps,
8/5/2020 4:34 PM>>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could you
please let us know what the current protocol is for that? Also, it's our understanding that hard drives with discovery
materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
f it would be helpful to discuss.
EFTA00031417

=== Page 2 ===
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
)"
Cc:
(NY) (FBI)"
(USANYS)"
Subject: Re: Epstein
Date: Mon, 10 Dec 2018 19:56:32 +0000
Attachments: Agg_Harrass_1996.pdf;
NATIVIDAD.pdf;
Event_Detail_-_ICAD_diff_breather.pdf;
None of the 911 calls were relevant. But here are some additional reports I pulled from that DAS search.
One contains information for an employee of
and the second is the property manager of the
location.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
,
Sent: Monday, December 10, 2018 2:31:58 PM
To:
Cc:
,
(NY) (FBI);
);
,
(USANYS)
Subject: Re: Epstein
1) I am working through these 911 calls but all of them so far come from his alarm company.
2) DAS search from that 212 number was negative results other then is SOMU report popped up.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
Sent: Monday, December 10, 2018 2:21:00 PM
To:
Cc:
(NY) (FBI);
);
(USANYS)
Subject: RE: Epstein
Thanks,
Much appreciated. Two quick questions:
1) Are you able to pull the supporting sprint reports for the 911 calls reported in the DAS report, or do we need to
subpoena NYPD communications?
2) Are you able to run a DAS search with Epstein's phone number
)
as well? Thanks.
Thanks!
EFTA00031361

=== Page 2 ===
From:
,
Sent: Monday, December 10, 2018 2:05 PM
To:
(USANYS)
Cc:
is
(NY) (FBI)
is
Subject: Re: Epstein
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
,
Sent: Monday, December 10, 2018 2:03:53 PM
To:
(USANYS)
Cc:
);
(NY) (FBI);
Subject: Re: Epstein
More Epstein reports
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
,
Sent: Monday, December 10, 2018 1:54:43 PM
To:
(USANYS)
Cc:
);
,
(NY) (FBI);
Subject: Re: Epstein
See attached SOMU records.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
(USANYS)
Sent: Monday, December 10, 2018 12:47:40 PM
To:
Cc:
);
(NY) (FBI);
Subject: Re: Epstein
EFTA00031362

=== Page 3 ===
Can we chat after 2? Otherwise go ahead without me and
will catch me up.
you are going to have to change your
name!
Sent from my iPhone
On Dec 10, 2018, at 12:46 PM,
<mailto:
wrote:
,
We are available now if you would like to call but I am on the road so you will have to conference us in separately.
On Dec 10, 2018, at 12:12,
)
<mailto:
wrote:
and
Any chance you're free for a brief call this afternoon? We wanted to touch base about a few items. I'm sure you're both
very busy in preparation for Wednesday, so we promise to keep it short.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
EFTA00031363


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein FOIA call
Date: Thu, 06 May 2021 16:04:56 +0000
Importance: Normal
Attachments: unnamed
EFTA00031624


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=== Page 1 ===
From:
To:
Bec: "USAHUB-USAJournal111"
Subject: RE: Draft bail opposition
Date: Mon, 14 Dec 2020 21:41:12 +0000
Embedded: RE:_Draft_bail_opposition.msg
Sender:
Subject: RE: Draft bail opposition
Message-Id:
<DM3P110MB045822AD8C1963DB941A90AA84C70@DM3P110MB0458.NAMP110.PROD.OUTLOOK.Q
OM>
To:
To:
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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status
Date: Mon, 03 Aug 2020 19:31:05 +0000
Attachments: evidenceStatus20200729.xlsx; ZeroByte_Files.xlsx
Embedded: RE:_IEXTERNAL_EMAILJ_-_RE:_Epstein_Evidence_status.msg
I know you may still be traveling, but I wanted to check in on a handful of outstanding issues. If you're not available,
perhaps
can assist?
-
On this past Sunday and Monday, you had said you had you had additional materials you planned to get to us on
Monday. I don't believe we ever received anything additional this past week. Are those still pending, and if so,
when can we get those materials?
-
There were three folders that were included in the first disc you provided to us, but then also provided again on
the most recent disc. Those folders are: NYC024328, NYC024366, and NYC024392. Can you please let us know
why those were provided twice? In particular, we need to know whether any supplemental information is in the
new folders with those NYC numbers, or whether we can ignore them on the recent disc because we already
received them.
-
One item is listed on your spreadsheet as having been provided on 7/23, but it was not on the most recent disc
you sent. That item is: NYC027913 (row 40 in your spreadsheet).
In case it's useful, I'm attaching a version of the spreadsheet you put on the disc, but with all the items we received
folders for on the most recent hard drive highlighted in yellow.
Separately, we're still waiting on answers to the questions from Thursday and Friday, July 23 and 24. To refresh, those
questions are:
-
Comparing your most recent spreadsheet to the prior one, and leaving aside the "Nothing for Southern"
designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're
looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional
devices listed here that weren't on the spreadsheet you previously sent. I have those as: NYC024328 (row 10),
NYC024367 (row 62), and NYC027910 (row 96). Please confirm that these were added, and also that we're not
missing any? I believe those were all provided on the first disc.
As previously mentioned, the vendor has advised that in the initial seven devices provided, there were
approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the second attached
spreadsheet. Is that accurate? Or does that reflect some issue with the extraction process?
thanks,
EFTA00029882

=== Page 2 ===
From:
Sent: Friday, July 24, 2020 15:09
To:
Cc:
is
is
is
is
is
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Evidence status
I don't have the evidence in front of me, but it is probably accurate. It is not unusual for the software to find such
files. I will review Monday to make sure. As to your questions from last night, the sheet should be
comprehensive. I only recall 1 addition, but I am sure that what I have is reflected in the sheet. As for the items
in dark grey, there are 2 servers with multiple drives. Some of those drives have physically failed. We have to get
them to one of our HQ specialists for recovery. Since they are physically broken, data recovery may or may not
be possible. It can be a very long process. We will get that moving ASAP. Need anything else, let me know.
On Jul 24, 2020 2:20 PM,
)"
wrote:
In addition to the pending questions below, we've been advised by the vendor that is reviewing the initial seven devices
(that were provided on a per-device extraction basis, as previously discussed) that those materials include approximately
71,000 documents that are zero bytes (i.e., empty files). They are listed in the attached spreadsheet.
Is that accurate? Or does that reflect some issue with the extraction process?
thanks,
From:
Sent: Thursday, July 23, 2020 18:08
To:
Cc:
i
is
is
is
Subject: RE: Epstein Evidence status
This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern"
designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at
(such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here
that weren't on the spreadsheet you previously sent. I have those as:
EFTA00029883

=== Page 3 ===
1. NYC024328 (row 10)
2. NYC024367 (row 62)
3. NYC027910 (row 96)
Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those
were included in the drive you provided today.
I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in
NYC024395 - could you please let us know what that means?
Thanks very much, and we'll circle back if any issues with anything we received today, which should get to
in the
next day or two.
thanks again,
Original Message
From:
Sent: Thursday, July 23, 2020 14:44
To:
-
Cc:
is
Subject: Epstein Evidence status
Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to
get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. Any
questions, let me know.
EFTA00029884


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=== Page 1 ===
From:
Subject: Accepted: Questions re: Epstein ESI
Date: Tue, 10 Mar 2020 22:32:41 +0000
Importance: Normal
Attachments: unnamed
EFTA00030301


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c2: DataSet 8
c3: VOL00008
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Date: Wed, 14 Jul 2021 17:36:08 +0000
Embedded:RE_Order_no_15JA5421F00000068_Scanning_project_U.S_v_Maxwell_Epstein.msg
Inline-Images: image001.jpg; image002.jpg
Hi
Sorry to bother you again. I just received response from CACI that no boxes were ever sent to them to be process.
I just wanted to confirm that part. If so, then we assume there is no billable expense and can go ahead and close the
contract?
Thanks!
From:
Sent: Thursday, June 24, 2021 3:55 PM
To:
(USANYS)
Subject: RE: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Hi
No, this is no longer needed.
Thanks very much,
From:
(USANYS)
Sent: Thursday, June 24, 2021 5:48 AM
To:
Subject: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Good morning
Is this document scanning service for the Maxwell/Epstein case still needed?
We haven't received any invoices from CACI, so I will also check with them.
Thanks,
From:
(USANYS)
Sent: Wednesday, March 24, 2021 2:24 PM
To:
Cc:
Subject: Delivery/Task order no. 15JA5421F00000068
EFTA00030760

=== Page 2 ===
Hi
Attached is a task order for CACI - Commercial services (scanning/document management) under GS-25F-
0131M; please retain for your records.
The period of performance of this contract is from 3/24/2021 - 5/31/2021. The total estimated value of this
contract is
If you have any contract related questions, please don't hesitate to contact me.
Please email all invoices and payment related questions to
Remember to include
the following information on your invoice correspondence:
Task order# 15JA5421F00000068
Reference# R21NYS18013
OF JUSTICE
Contract Specialist (FAC-C/COR III)
U.S. Attorney's Office, Southern District of New York
86 Chambers St. /New York, N.Y. 10007
T:
I
F:
E-Mail:
EFTA00030761


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=== Page 1 ===
STATE
STATEMENT
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 18, 2020
BY HAND & EMAIL
MDC-Metropolitan Detention Center
Legal Department
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
Enclosure
EFTA00029979


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c3: VOL00008
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c0:
=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
(USANYS)"
i
(USANYS)"
, "
(USANYS)"
(USANYS)"
,
(USANYS)"
Cc:
)"
,
)"
Subject: Revised Maxwell Indictment
Date: Thu, 25 Jun 2020 13:42:36 +0000
Attachments: : 2020-06-25_Maxwell_draft_indictment.docx
All,
Attached please find the most recent draft of the Maxwell indictment, which incorporates the most recent round of edits
we received.
Thanks,
EFTA00029795


c1: EFTA00031419
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031419.pdf
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c0:
=== Page 1 ===
From:
SANYS)"
To:
(USANYS)"
Cc:
)"
Subject: Re:
Date: Thu, 04 Jun 2020 14:01:54 +0000
Will do. Thanks.
Sent from my iPhone
On Jun 4, 2020, at 10:00 AM,
(USANYS)
wrote:
That makes sense to me.
why don't you have it sent to me and we will go from there?
From:
(USANYS)
Sent: Thursday, June 04, 2020 9:57 AM
To:
(USANYS)
Cc:
USANYS)
Subject: Re:
Hi
I spoke with
about this the other day. Apparently the disc was left with a note saying it had evidence of Epstein's
"murder," so I expect this is entirely to do with the death. That's why I suggested he reach out to
My suggestion would be that this go to your team first, and then you can pass it on to us if you think it's relevant to our
sex abuse investigation.
Thanks,
On Jun 4, 2020, at 9:53 AM,
(USANYS)
wrote:
I'm adding
to this email chain, as she's on the actual Epstein investigation.
can you send your
mailing address to
if you could have copies made of the disc, you could send it to both of us. Otherwise, if you only have one copy,
I'm happy to review and make sure it gets to the right place.
From:
(USANYS)
Sent: Thursday, June 04, 2020 9:48 AM
To:
(USANYS)
Subject: RE:
Hi
I didn't realize you weren't on this one. I'll send this to you. Let me know if I should send it to someone else.
EFTA00031419

=== Page 2 ===
From:
(USANYS)
Sent: Wednesday, June 03, 2020 6:45 PM
To:
(USANYS)
Subject: Re:
That's fine, although I'm on the MCC guard case, not the Epstein investigation. Do you have any sense if it's related to
his conduct or his death? Either way, you can send it to me at the following address:
Hope you and your family are well!
Sent from my iPhone
On Jun 3, 2020, at 5:06 PM,
(USANYS)
wrote:
Hi
Hope you are well
who teaches at Pace, had someone drop off to her a note and a CD which
they claim somehow relates to Epstein. No clue what's on it. How can I send this to you? Thanks.
EFTA00031420


c1: EFTA00030638
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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
(USANYS)"
Subject: FW: Redactions to MILs
Date: Wed, 03 Nov 2021 04:40:28 +0000
Attachments:Jury_Instructions_Govt_Proposed_Defense_Redlines_[202111.01J.DOCX;
Jury_Instructions_Govt_Proposed_Defense_Redlines_[2021.11.01
Hey Chiefs,
They sent us the rest of their redline, if you'd like to take a look.
I've also attached a partial set of responses. I'll get you the rest ASAP tomorrow, but we're tight on timing, so here's about
half of it now. Two points about it:
1. I wasn't sure whether you wanted to see every change, so I've put comment bubbles even where I think we should
just accept the changes.
2. In their new redline as of tonight, they are proposing to do each count in order. We won't have time to implement
that by tomorrow, but we should think about whether to keep it as is or agree to their proposal.
This is due today (Wednesday), and the defense has significantly blow their deadline to get this to us. If it would help, we
can seek an extension on that basis.
Last, as you can see, they insist on putting our victims' names in filings. We are thinking of proposing to the defense that
they just note in a footnote their continued objection but stop using the names. Otherwise, we'd like to talk about going
to the Court. Their practice is (1) burdensome to make us redact all their filings, and (2) an invitation for us to miss
something and out a victim.
Thanks,
From: Christian Everdell
Sent: Wednesday, November 3, 2021 12:19 AM
To:
Cc:
is
is
(USANYS)
is
)
>; Jeff Pagliuca
>; Laura Menninger
is
Subject: [EXTERNAL] RE: Redactions to MILs
Attached is the full redline of the RTCs. I made some changes to the sections I already sent you. Those are highlighted in
yellow. I will send you the verdict sheet later tonight.
Regarding the "Minor-Victim" terminology, I know the redactions are a pain, but it is still our position that there is no
need to anonymize them and we object to calling them both "minors" and "victims." So I can't agree to that.
Thanks,
EFTA00030638

=== Page 2 ===
Chris
From:
Sent: Tuesday, November 2, 2021 6:35 PM
To: Christian Everdell
Subject: RE: Redactions to MILs
Hi Chris,
Just checking in on when you think you might have the rest of the RTC over to us.
Also, do you have any objection if we edit the places where your redline uses victim names to the "Minor Victim-X"
terminology? Our understanding is that we have to file this on ECF, and we just want to avoid having to redact anything.
Thanks,
From: Christian Everdell
Sent: Tuesday, November 2, 2021 3:43 PM
To:
Subject: [EXTERNAL] Re: Redactions to MILs
Do you have a minute for a quick call about the jury instructions? Should take 5-10 mins.
Thanks,
Chris
Sent from my iPhone
On Nov 2, 2021, at 12:44 PM,
)
wrote:
Counsel,
We're preparing a new version of the proposed redactions to the MILs that withdraw some of our proposals. Please let
us know which if any of your proposed redactions you would like to withdraw, and whether you would like to see our
version before we send it to the Court. In particular, please let us know by Thursday at 10 a.m. so we have some time
before this is due to the Court.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00030639


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
Subject: Read: US V. Epstein
Date: Mon, 10 Jun 2019 16:27:54 +0000
Importance: Normal
EFTA00030288


c1: EFTA00029660
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c3: VOL00008
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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE:
3500
Date: Fri, 27 Aug 2021 22:49:18 +0000
All set, thanks
Subject:
3500
Hi,
Would you please save the attached in
3500 and witness folders on the Epstein share?
Thanks!
EFTA00029660


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: RE: Extradition
Date: Sun, 13 Dec 2020 23:49:01 +0000
Attachments: Bail_Section_LEP_(Comparator_Cases).docx
Hi - See attached. Again, please feel free to edit as you see fit. Happy to discuss. Thank you!
From:
(USANYS)
Sent: Sunday, December 13, 2020 3:16 PM
To:
Subject: Extradition
Here you go - please feel free to edit
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00031817


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=== Page 1 ===
Event: Accepted:
counsel call
Start Date: 2019-07-09 14:00:00 +0000
End Date: 2019-07-09 14:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-07-08 02:40:51 +0000
Date Modified: 2019-07-08 02:40:51 +0000
Priority: 5
DTSTAMP: 2019-07-08 02:36:47 +0000
EFTA00030225


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=== Page 1 ===
From:
To:
Subject: sars
Date: Fri, 16 Aug 2019 02:39:09 +0000
Attachments: 31000152382969_transcript.pdf; 31000152314782_transcript.pdf
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00031004


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=== Page 1 ===
From:
)"
To: Jeffrey Pop
Cc:
)"
)"
Subject: RE: SDNY investigation,
Date: Sat, 04 Jan 2020 04:36:43 +0000
Inline-Images: image001.jpg
Jeff,
Thank you for this - it's extremely thorough and helpful, especially for an initial description, and we appreciate you
sending it so promptly. We also appreciate Ms.
willingness to share this information with us, which is
obviously very personal but which meaningfully assists our investigation.
In the first instance, on an initial read, I wanted to advise that this information does not alter our view, which I also
conveyed via email on December 24, that we do not currently have reason to believe Ms.
has criminal exposure
based on what we are aware of in connection with her interactions with Epstein. Additionally, I do expect we likely will
have some follow-up queries; we'll circle back with you in more detail next week, but in the interim I wanted to
acknowledge receipt and thank you for conveying. We'll be in touch again soon.
Assistant U.S. Attorney
Southern District of New York
From: Jeffrey Pop
Sent: Friday, January 03, 2020 18:35
To:
Cc:
is
Subject: RE: SDNY investigation,
Dear
:
Attached, in letter format, please find a version of an Attorney Proffer regarding
and her
involvement with Epstein. At the end, I have also included an outline of
current perception as to
how he operated.
The foregoing is a culmination of a series of interviews with my client and I believe that it represents her
potential testimony. Obviously, I am not certain whether any of the information presented is new to you or
helpful to your investigation.
My take away is that there is no doubt that
is a victim; she suffers to this day. At the same time there
were other people looking to introduce girls to Epstein. This pattern apparently was ongoing for decades.
introduction involvement was only in New York and not with minors.
was shocked when
she found out that Epstein was arrested in Florida.
EFTA00030695

=== Page 2 ===
Should you feel that an interview is necessary, please propose a couple of dates before January 20, 2020 (I
have an upcoming trial in late January). I will make my conference room available for the interview.
Let me know if you have any questions.
Sincerely,
Jeff
Jeffrey S. Pop, Esq.
JEFFREY S. POP & ASSOCIATES
Beverly Hills, California 90212-3429
fax
www.poplawyer.com
www.vaccineinjuryteam.com
JEFFREY S. POP & ASSOCIATES
A LAW CORPORATION
Since 1980
CONFIDENTIALITY
This e-mail is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from Jeffrey S. Pop & Associates. Its contents are not only to
remain absolutely confidential, but may also be subject to the attorney-client privilege or coverage under the work-product doctrine. If you have received this transmission and
are not the intended recipient(s) or his/her agent, please be advised that any disclosure, use, review, copying, selling, dissemination, publication, or distribution of this
transmission is strictly unauthorized and prohibited. If you have received this transmission in error, please notify the sender at the number above, return the original e-mail by
mail, and delete the e-mail file from your computer. Postage is guaranteed. Your cooperation is appreciated. Thank you.
From:
) [mailto:
Sent: Monday, December 23, 2019 9:34 PM
To: Jeffrey Pop
Cc:
);
)
Subject: RE: SDNY investigation,
Jeff,
Following up on our phone conversation today, I wanted to memorialize that, as discussed, we do not currently have
reason to believe Ms.
has criminal exposure based on what we are aware of in connection with her interactions
with Jeffrey Epstein, and your brief attorney proffer regarding the circumstances of those interactions are consistent with
that view. In your further discussions with Ms.
in advance of a further attorney proffer to address the general
nature of her relationship with Mr. Epstein, as well as his employees or relevant close associates, if you have any concerns
about additional possible exposure you should please feel free to be in touch with us again. As we also discussed, I
believe any non-federal offenses would be well outside the relevant statute(s) of limitation, but of course if you wish to
further research that issue, or consult with criminal counsel, we defer to you entirely.
Please let us know if any other information would be useful at this stage, and hopefully we can be in touch in the coming
weeks about productive next steps.
thank you,
EFTA00030696

=== Page 3 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00030697


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=== Page 1 ===
From:
)"
To:
Subject: RE: 9 E 7 1st Street New York NY DEED
Date: Thu, 27 Jun 2019 18:05:58 +0000
Importance: Normal
Hey thanks for this, only thing is that whatever he attached didn't come through - could you forward the attachment(s)?
Thanks!
From:
Sent: Thursday, June 27, 2019 13:59
To:
Cc:
>;
)
>;
>;
Subject: Re: 9 E 71st Street New York NY DEED
Thanks for this info. I've cc'd my partner, along with the AUSAs that we are working with so they have it as
well.
Thanks again,
Mandy
-
On Jun 27, 2019 1:44 PM,
wrote:
Hi Mandy
This is from ACRIS. It's the Last Deed of Record, dated 12/23/2011.
Notice that the Grantor and Grantee lines are both signed by Jeffrey Epstein.
The Grantee is Maple Inc which is located in St Thomas, VI.
No mortgages from Maple Inc are indicated in the online records.
EFTA00030222


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=== Page 1 ===
From:
To:
Subject: Emails for Discovery
Date: Fri, 09 Oct 2020 17:44:24 +0000
Embedded:
.msg; Wilton_Manors_Police_Dept-
Re:_Any_luck_buddy?.msg; Any_luck_buddy?_msg;
msg; Re:_Hi_There,msg; Hi_There,.msg, Hi_there...nsg;
Fw:_FYI_-_see_attachment.msg; Re:_Photos.msg
Hi All,
Hopefully this works. Please confirm you are able to review. If not, I will scan and email instead.
Regards,
EFTA00030585


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From:
)"
To:
)"
(
)"
Subject: RE: New Investigation
Date: Thu, 06 Dec 2018 23:21:56 +0000
Importance: Normal
Same, can chat in person tomorrow and was a brief but good meeting with the agents.
Original Message
From:
Sent: Thursday, December 06, 2018 18:10
To
Cc:
Subject: RE: New Investigation
No worries, happy to talk any time.
Original Message
From:
(
)
Sent: Thursday, December 6, 2018 6:04 PM
To:
Cc:
Subject: Re: New Investigation
Sorry I missed this. I am super annoyed. Just got out of mag court. Running home to feed the baby. But I am
around later tonight or tomorrow afternoon when I come back from white plains.
Sent from my iPhone
> On Dec 6, 2018, at 5:46 PM,
)
wrote:
Thanks for taking the time to meet today-attached are the documents we mentioned.
> From:
,
N. (NY) (FBI)
> Sent: Thursday, December 6, 2018 1:40 PM
V V V V V V V V V V V V V
> To:
> Cc:
)
Subject: Re: New Investigation
I am still in NJ. I have everything we have downloaded to CD. It's at the office. I can bring it when we meet.
Original message
> From:
<mailto:
,
EFTA00031462

=== Page 2 ===
> Date: 12/6/18 1:38 PM (GMT-05:00)
> To:
)"
<mailto:
> Cc:
)"
<mailto:
(
)"
<mailto:
N. (NY) (FBI)"
<mailto:
> Subject: Re: New Investigation
>
> I'm in the proffer and do not have the disc with me. If I'm not mistaken
may still be in NJ. If I finish up
over here earlier then expected I'll ran back and grab it.
V
> On Dec 6, 2018, at 12:59,
)
<mailto:
wrote:
> Hi all-looking forward to meeting this afternoon. If you're able to bring over a copy of the files on this case
(we'll take as much stuff as possible!), we'd really appreciate it. CD or drive are both fine.
>
>
Thanks!
>
> From:
)
<mailto:
> Sent: Tuesday, December 4, 2018 7:19 PM
> To:
<mailto:
>>:
(
<mailto:
N. (NY) (FBI)
<mailto:
> Cc:
)
<mailto:
>
Subject: RE: New Investigation
V
> No worries at all, and I'll make 4:30 work.
>
V
>
From:
<mailto:
,
> Sent: Tuesday, December 04, 2018 19:16
> To:
<mailto:
<mailto:
>;
N.
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: Re: New Investigation
V
V
> I have child care issues in the mornings typically, and getting in by 11:00 is often difficult as I live in Suffolk
County. 4:30 works better for me. Sorry about that!
V
V
V
> Detective
V
> NYPD / FBI
V
> Child Exploitation Human Trafficking Task Force
V
> Office:
V
> Cell:
V
> Fax:
EFTA00031463

=== Page 3 ===
> > > > >
> From:
)
<mailto:
Sent: Tuesday, December 4, 2018 7:06:28 PM
> To:
(
);
N. (NY) (FBI)
> Cc:
)
> Subject: RE: New Investigation
>
I unfortunately have calls at 4:00 and 4:30. Could we do earlier before 11:00? I'm also concerned that if the
proffer ends up going late we'll be out of luck. Or I can move the 4:30 if that's preferable for everybody. Sorry
about that.
>
>
>
V
>
> From:
<mailto:
,
> Sent: Tuesday, December 04, 2018 19:04
> To:
<mailto:
>>;
)
<mailto:
>;
N.
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: Re: New Investigation
V
>
>
> 11:00 will not work for me. Me and
are good for 4:00 on Thursday though. The proffer should be done
by then.
>
V
>
>
Detective
>
> NYPD / FBI
>
V
Child Exploitation Human Trafficking Task Force
V
>
Office:
V
> Cell:
V
> Fax:
V
V
V
>
From:
)
<mailto:
> Sent: Tuesday, December 4, 2018 6:34:53 PM
> To:
(
);
N. (NY) (FBI)
> Cc:
)
> Subject: RE: New Investigation
>
EFTA00031464

=== Page 4 ===
V
>
> Let's do Thursday, particularly since schedules seem to be tough next week.
would it make sense to meet
,
before your proffer, so we can have a specified time? We could meet at 11:00.
> > > > > > > > >
thanks,
> From:
<mailto:
,
> Sent: Tuesday, December 04, 2018 15:54
> To:
<mailto:
>;
,
N. (NY) (FBI)
<mailto:
> Cc:
<mailto:
)
<mailto:
> Subject: Re: New Investigation
>
>
V
> Hey guys,
V
V
V
> Thursday I have a proffer at SNDY with SA
at 12:00. I can meet after that if you guys want depending
on how long this proffer goes. That may be the best option for us because Monday-Wednesday of next week we
may be tied up with a take down in the office.
V
V
>
> Detective
>
> NYPD / FBI
>
>
Child Exploitation Human Trafficking Task Force
>
V
Office:
V
> Cell:
>
> Fax:
V
V
V
> From:
(
)
<mailto:
> Sent: Tuesday, December 4, 2018 3:30:14 PM
> To:
N. (NY) (FBI);
> Cc:
);
)
> Subject: RE: New Investigation
V
V
EFTA00031465

=== Page 5 ===
V
>
Thursday works for me.
V
V
V
>
Next week I am good Monday-Tuesday and Thursday-Friday.
V
V
V
> From:
N. (NY) (FBI)
<mailto:
> Sent: Tuesday, December 04, 2018 3:23 PM
> To:
(
<mailto:
(
<mailto:
<mailto:
> Cc:
<mailto:
<mailto:
>
Subject: RE: New Investigation
V
>
>
> Hey
V
>
>
> The only day I'd be free this week would be Thursday. Next Wednesday is not good, but any other day next
week I should be ok right now.
V
>
>
> I'm also working on putting everything we currently have onto a disk for you, so I should have that for you
when we meet.
>
V
>
> From:
(
) [mailto:
> Sent: Tuesday, December 04, 2018 2:14 PM
> To:
N. (NY) (FBI)
<mailto:
>;
,
(NY)
(OGA)
> Cc:
)
<mailto:
>;
<mailto:
V
Subject: RE: New Investigation
>
V
V
V
good speaking with you. I understand that you and
were just assigned the case yesterday and are
just starting to dig in. As we discussed I think it makes sense for us all to get into a room together son and chat.
V
V
V
V
When works for you guys?
V
V
V
> From:
(
)
EFTA00031466

=== Page 6 ===
> Sent: Monday, December 03, 2018 5:51 PM
> To:
,
N. (NY) (FBI)
<mailto:
(NY)
(OGA) (FBI)
> Cc:
<mailto:
>;
)
<mailto:
> Subject: New Investigation
V
V
V
>
and
,
V
V
V
>
We got the package you dropped off today. Thank you. CC'ing the other members of the team on this email.
V
>
V
> Best,
V
V
V
>
V
>
V
>
>
>
Assistant United States Attorney
V
>
Human Trafficking Co-Coordinator
>
>
Violent & Organized Crime
>
>
Southern District of New York
V
V
V
V
V
<Palm Beach Police Reports.pdf>
V
<Epstein Blackbook.pdf>
> <Flight Logs.pdf>
EFTA00031467


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c0:
=== Page 1 ===
From:
"
To:
)"
(
)"
Cc:
)"
)"
=
)"
i
)"
,
)"
Subject: Re: Epstein
Date: Thu, 15 Aug 2019 19:35:54 +0000
All providers have been contacted and are expediting your requests. Just a heads up we may be out of luck with the IPV4s though.
From:
(
Sent: Thursday, August 15, 2019 2:33 PM
To:
(
Cc:
(
>;
is
is
;
(
is
is
Subject: RE: Epstein
Hi team, just letting you know that I asked
cc'd here, to help us get expedited subpoena returns from the phone companies,
which he is working on.
EFTA00031003


c1: EFTA00030692
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c3: VOL00008
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c0:
=== Page 1 ===
From:
Subject: RE: U.S. Department of Justice investigation
Date: Tue, 07 Jan 2020 16:28:39 +0000
Inline-Images: image001.jpg; image002.jpg
Works for me, thanks.
From:
Sent: Tuesday, January 7, 2020 11:28 AM
To:
V.
Subject: RE: U.S. Department of Justice investigation
Could we possibly do 9 a.m. on Friday (given the time-zone and availability). I have a proffer starting at 10. If not, no
worries, happy for you guys to go ahead if that's easier.
From:
Sent: Tuesday, January 7, 2020 11:22 AM
To:
y.
Subject: FW: U.S. Department of Justice investigation
I'm available all day on Friday.
From: Gary Bloxsome
Sent: Tuesday, January 7, 2020 11:20 AM
To:
Cc:
is
>; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
Kind regards.
Gary
Gary Bloxsome
Partner
RANKED IN
Chambers
LEGAL
UK
500
KINGDOM
www.blackfords.com
2020
TOP TIER
Leading Firm
2020
EFTA00030692

=== Page 2 ===
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint
Walk, Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 4 Jan 2020, at 01:38,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally, in
connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to request
a consensual, voluntary law enforcement interview with your client. Generally, we would expect to inquire about his
relationship and communications with Jeffrey Epstein and his associates, as well as certain allegations that have arisen
publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law enforcement
channels, we understand we may also alternatively inquire directly with counsel, when an individual has legal
representation. Given your representation, we are inquiring directly with counsel in the first instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were seeking as a
threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
Gary Bloxsome
Partner
EFTA00030693

=== Page 3 ===
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jan 2020, at 18:54,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of Justice,
Southern District of New York. We have been advised that you currently represent HRH The Duke of York. Could you
please advise whether that is correct? We - my colleagues
and I - can be reached
anytime at these email addresses, or please let us know if you would prefer to set up a time to discuss via phone.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00030694


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=== Page 1 ===
From:
To:
Subject: RE: Private & confidential
Date: Tue, 07 May 2019 20:48:17 +0000
Importance: Normal
Received, thanks very much.
From:
Sent: Tuesday, May 07, 2019 16:47
To:
Subject: FW: Private & confidential
Not sure this is terribly significant, but forwarding it to you just in case.
Best,
I
Criminal Division
From:
Sent: Tuesday, May 7, 2019 4:44 PM
To
Subject: Private & confidential
http://www.virginislandsdailynews.com/news/epstein-building-compound-on-great-st-james/article_a49261e9-
40f0-57b1-9501-605e26e74cf3.html
Executive Director
Alliance to Rescue Victims of Trafficking
atrvt.org
EFTA00031314


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=== Page 1 ===
From:
(
]"
To:
)"
Subject: RE: Discovery Requests
Date: Wed, 03 Feb 2021 20:00:07 +0000
Inline-Images: image001.jpg; image002.jpg
For reference, the tracking numbers are
) and
- thanks! © ©
From:
)
Sent: Wednesday, February 3, 2021 2:56 PM
To:
(
Subject: RE: Discovery Requests
Great, thank you!
From:
(
Sent: Wednesday, February 3, 2021 1:07 PM
To:
Subject: RE: Discovery Requests
Hi
!
I've loaded the flash drive with the bates ranges defense counsel requested, and it will be ready to leave for
pickup momentarily. The password for the drive is
!
I'm about to start loading a disc with the Ninth Production and re-stamped items for MDC now. l'll let you know when that
has been left for FedEx pickup this afternoon. Thank you!
From:
Sent: Tuesday, February 2, 2021 8:54 AM
To:
(
is
Subject: RE: Discovery Requests
Perfect, thank you!
From:
(
Sent: Tuesday, February 2, 2021 8:36 AM
To:
is
(
Subject: RE: Discovery Requests
Good morning! If it's okay with everyone, I will be in the Office tomorrow and can load this drive (and the disc for MDC
with the latest Ninth Production) then. Thanks very much!
From:
Sent: Monday, February 1, 2021 2:34 PM
To:
(
i
(
Subject: FW: Discovery Requests
EFTA00030926

=== Page 2 ===
FYI. I'm not going to be able to come into the office this week. Will someone be in and able to check the mail for this
drive and get it loaded?
From:
Sent: Sunday, January 31, 2021 10:41 PM
To:
is
is
(USANYS)
Cc:
Subject: RE: Discovery Requests
Hi
-
We will provide you with a drive to load the files. If our messenger service is functioning tomorrow (depending on the
severity of the snow storm) we will drop it off tomorrow. If not, we will drop it off Tuesday morning.
Thanks,
From:
) [mailto:
]
Sent: Friday, January 29, 2021 4:41 PM
To:
Subject: RE: Discovery Requests
Our paralegals reminded me that we have produced the ranges you included in your most recent email twice: once in the
third production (08-21-2020) and once in the reproduction with shortened file names (09-03-2020). We can certainly
produce them a third time, but we would not be able to reproduce them again through your FTP link, as they are too
large. Please provide us with a 64 GB drive if you would like us to reproduce those ranges.
Best,
Assistant United States Attorney
Southern District of New York
0007
212-637-2324
From:
Sent: Friday, January 29, 2021 4:08 PM
To:
i
)
is
(USANYS)
Cc:
>
Subject: RE: Discovery Requests
EFTA00030927

=== Page 3 ===
Thank you for sending the link. I will ask our paralegals to use it to send you the ranges you requested, including the
ranges you referenced in your most recent email.
Best,
Assistant United States Attorney
Southern District of New York
From:
>
Sent: Friday, January 29, 2021 3:53 PM
To:
)
is
)
<
V.
(USANYS)
Cc:
<
>
Subject: RE: Discovery Requests
-
Thanks for the follow-up. Please send the documents to the FTP link below:
Also, we are missing the Bates ranges listed below.
SDNY_GM_00167911 through SDNY_GM_00168477
SDNY_GM_00168488 through SDNY_GM_00169165
SDNY_GM_00169184 through SDNY_GM_00169491
SDNY_GM_00169505 through SDNY_GM_00169735
We had discussed these ranges several months ago and I believe you had agreed to reproduce them in the 11/9
production. But we do not appear to have received them. Can you send these ranges via the FTP site as well?
Thanks,
From:
) [mailto:
Sent: Friday, January 29, 2021 10:31 AM
To:
Subject: RE: Discovery Requests
EFTA00030928

=== Page 4 ===
Following up on this, we have now prepared all of the items you requested in point 6 below for production to you. Our
paralegals have sent a copy of the materials to the MDC for your client. Would you like to provide us with an FTP link for
this production, or would you like us to prepare a CD for you instead?
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Monday, January 25, 2021 3:56 PM
To:
is
)
is
(USANYS)
Cc:
>
Subject: RE: Discovery Requests
Following up on point 6 below, our paralegals have re-stamped the materials you identified with a Bates range overlap
and are prepared to reproduce those materials to you. The materials are small enough to produce via your FTP site.
Would you like to send us a link to where you would like those materials uploaded? Alternatively, we can load the
materials to a CD and send it to you.
We are still waiting to hear back from our vendor about the remaining issues you identified in point 6.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Sunday, January 17, 2021 10:05 PM
To:
i
is
EFTA00030929

=== Page 5 ===
(USANYS)
Cc:
Subject: RE: Discovery Requests
Below please find our responses.
1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery
produced to date. It took a significant amount of time to create this copy due to the volume of discovery and
delays on the part of our vendor, who assisted in creating the copy.
2. As we have recently discussed, Ms. Maxwell now has a drive containing the contents of the CD produced on
November 18, 2020.
3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all
contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was
extracted. In our November 18, 2020 discovery letter, we provided you with a chart setting forth which "NYC"
CART Evidence Number corresponds with which Subject Device in our warrants. If you still need a detailed index
of all 1.2 million documents with the specific Subject Device indicated, please let me know, and I will ask one of
our paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein's devices. In other words, we did not apply any redactions to that document;
rather, the redactions existed on the document at the time the document was found during the FBI's search of
Epstein's devices. We are not aware of any legal basis for your request for a log of redactions. If you have any
legal authority on that point, we would be happy to consider it. As a courtesy, I will note that our office did not
apply redactions to any material that was identified responsive during the searches of Epstein's devices.
5. We are aware of our discovery obligations, have complied with them, and will continue to comply with them. We
are not aware of any legal basis for your request that we inform you of what, if any, documents have been
withheld or the basis for their withholding. If you have any legal authority on that point, we would be happy to
consider it. As a courtesy, I will note that we have provided you with all records we received from
and all
records we received from
As to your inquiry about the Bates ranges on the
documents
beginning with Bates number "28", I note that the folder containing the
subpoena returns in our August
5, 2020 production included two documents. The first (SDNY_GM_00005532-5649) is the document you
referenced in your email inquiry. The second (SDNY_GM_00005650-5676) is 27 pages long, accounting for the
first 27 pages of the production from
We produced those two documents in the form in which we
received them.
6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach
back out to you once I have an update on the status of those issues.
7. We do not have a more detailed index of the November 9 and November 18 productions beyond what we have
provided to you.
8. We are not aware of any legal basis for your request for copies of grand jury subpoenas. Nor are we aware of any
legal basis for your request that we identify the date range of documents we requested in each subpoena. If you
have any legal authority for those requests, we would be happy to consider it.
9. The court filings that appear to be referenced in the Daily Beast article you sent are an application for a search
warrant and a search warrant filed in the District of New Hampshire. We produced both documents to you in
discovery on August 5, 2020. The DNH judge issued a sealing order in connection with the warrant and
EFTA00030930

=== Page 6 ===
application. As you can see at Bates No. SDNY_GM_00000621, the sealing order automatically expired on
December 30, 2020. Our understanding is that the District of New Hampshire unsealed the filing of its own
accord in conformity with the clear language of that sealing order. Our office took no affirmative steps to unseal
or otherwise release these filings.
Best,
Assistant United States Attorney
Southern District of New York
From:
Sent: Thursday, January 7, 2021 4:13 PM
To:
is
V.
(USANYS)
Cc:
Subject: Discovery Requests
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery
production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms.
Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive
will be ready?
2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the
MDC (as you know, the laptop provided to Ms. Maxwell does not have a CD drive). Accordingly, we asked you to
include the material on the CD in the new 4TB hard drive. We followed-up with you about this issue on December
30, 2020. Given that the new hard drive is still not ready, we ask that you download the material on the CD onto
a separate thumb drive or hard drive and provide it as quickly as possible to Ms. Maxwell at the MDC so that she
can review the materials this weekend. Alternatively, you can provide an external CD drive to Ms. Maxwell at
the MDC so that she can read the files on the MDC computer. We will provide whatever media device you
require to facilitate this production.
3. Unlike the November 9, 2020 discovery cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover letter indicates that the documents came from "SDNY_PROD015" or "SDNY_PROD016." We do
not know what those terms refer to. We request that the government produce a list that correlates the Bates
numbers for all of the documents in SDNY_PROD015 and SDNY_PROD016 to the particular devices from which the
documents were recovered.
4. We request that the government provide an unredacted version of the FBI report, dated December 6, 2006,
bearing Bates number SDNY_GM_02050812-14 (attached). We also request that the government produce a log
EFTA00030931

=== Page 7 ===
identifying all of the redacted documents in the discovery and the bases for each of the redactions.
5. There are a few documents that seem to be missing from the discovery. For example, the
documents
(SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also,
the flight logs produced by
begin at Bates number
suggesting that
were not produced to us. Please produce these documents to us or provide an
explanation why you are not producing them to us. Please confirm whether there are other documents that were
removed from the grand jury subpoena productions that we have not yet identified and the basis for their removal.
6. There are a few Bates number/metadata issues with some of the documents:
a. There is an overlap between the fourth and fifth document productions. The fourth production ends at
SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the
range from the fifth production (i.e., renumber SDNY_GM_00328070-328863).
b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel
file. We propose that you send us a new DAT file covering only the missing documents.
C. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981.
We propose that you send us a new DAT file covering only the missing documents.
7. To the extent that the government has created an index of the documents produced on November 9 and
November 18 that is more detailed than the production cover letters, we request that you provide a copy to the
defense.
8. We request that the government provide copies of the grand jury subpoenas for documents issued by the
government in this case. Also, please identify the date range of documents you requested in each subpoena.
There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit
for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how-
the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared
in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on
the court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the
criminal discovery, and whether any discovery materials were released pursuant to FOIA requests.
Regards,
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York Paris Washington DC London
CG
EFTA00030932

=== Page 8 ===
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.
EFTA00030933


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=== Page 1 ===
From:
"
)"
To:
)"
)"
)"
)"
111
i
,
)"
Cc:
)"
i
)"
Subject: RE: RE: draft press release
Date: Tue, 30 Jun 2020 21:37:59 +0000
Attachments: 2020-06-30,_GM,_press_release_draft.docx
Let's try this one more time, with a couple typos fixed (including that CONPSIRACY is not a real word).
From:
Sent: Tuesday, June 30, 2020 17:25
To:
is
>;
is
is
is
is
Cc:
in
Subject: RE: draft press release
Team,
Attached is a draft press release for the Maxwell arrest - hopefully for tomorrow or Thursday at the latest. Happy to
incorporate any edits.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00030011


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=== Page 1 ===
From:
)"
To:
)"
Subject: Fwd: SDNY investigation
Date: Wed, 08 Jul 2020 00:06:41 +0000
Attachments: 2020-06-29,_subpoena_to_UBS.pdf,ATT00001.htm
Hey, I can't tell from the email threads whether this UBS subpoena covers the Angara trust. Do you know? It
isn't listed by name but I don't know what the account numbers are. Thanks!
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: July 7, 2020 at 2:04:14 PM EDT
To:
Cc:
)"
,
)"
Subject: SDNY investigation
Mr. Wills,
I'm reaching out in connection with the attached subpoena, which was served on UBS last week. If possible, we would
like to speak with someone in your compliance department to discuss expediting these materials. This matter is time
sensitive, and if possible, we would very much appreciate being able to speak with someone this afternoon. I'm also
copying Mr. Ryan, who I understand has assisted with prior productions to our office in connection with this same
investigation.
I can be reached at
at any time, and I'm copying my colleagues,
and
who
can be reached at
and
respectively.
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
:
(USANYS)"
Cc:
(USANYS) [Contractor]"
Subject: Judge Rules on Redactions to Filing in Ghislaine Maxwell Case
Date: Fri, 19 Mar 2021 01:41:46 +0000
https://lawandcrime.com/high-profile/judge-rules-some-ghislaine-maxwel-details-are-too-sensational-and
impure-to-be-revealed-to-the-public/
Sent from my iPhone
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=== Page 1 ===
From: Figgins Law Office
<f
To:
Cc:
i
Subject: USA V. Michael Thomas, et al.; Motion to Compel Discovery
Date: Fri, 03 Apr 2020 22:52:57 +0000
Attachments: Michael_Thomas_Motion_to_Compel_Discovery_and_Exhibits.PDl
Counsel,
Please see attached Defendant, Michael Thomas, Motion to Compel Discovery. Motion was
also filed via ECF.
--
Law Offices of Montell Figgins, LLC
17 Academy Street, Suite 305
Newark, NJ 07102
140 East Ridgewood Ave, Suite 415
Paramus, NJ 07652
Phone: (973) 242-4700 I Fax: (973) 242-4701
E
Montell Figgins Attorney At Law
This email communication and any files transmitted with it contain privileged and confidential information from the Law
Offices of Montell Figgins, LLC and are intended solely for the use of the individuals or entity to whom it has been addressed.
If you are not the intended recipient, you are hereby notified that any dissemination or copying of this email is strictly
prohibited. If you have received this email in error, please delete it and notify the sender by return email.
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
CASE NO: 19-cv-10475-LGS-DCF
V.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN and
GHISLAINE MAXWELL,
Defendants.
PLAINTIFF
NOTICE OF DEPOSITION
OF DEFENDANT GHISLAINE MAXWELL
PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30, Plaintiff
,
by and through her attorneys, will take the oral deposition of Defendant Ghislaine
Maxwell on April 29, 2020, beginning at 10:00 a.m. Eastern Standard Time at the offices of
Boies Schiller Flexner LLP,
unless the parties mutually
agree to hold the deposition on a different date or time and/or at a different location.
The deposition will be taken before a duly qualified notary public or other officer
authorized by law to administer oaths and record testimony pursuant to Federal Rule of Civil
Procedure 28. The deposition will be recorded by video, audio, and stenographic means. The
deposition may be used to preserve testimony for trial, to obtain discovery, and for any other
purpose authorized by the Federal Rules of Civil Procedure.
EFTA00030306

=== Page 2 ===
Dated: March 24, 2020
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies Schiller Flexner LLP
David Boies
Boies Schiller Flexner LLP
Joshua I. Schiller
Andrew Villacastin
Sabina Mariella
Boies Schiller Flexner LLP
Counsel for
2
EFTA00030307

=== Page 3 ===
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing Notice
of Deposition has been provided by electronic mail to all counsel of record identified below, on
this 24th day of March, 2020.
Laura Menninger, Esq.
HADDON MORGAN FOREMAN P.C.
Tel:
Fax:
Email:
Counsel for Defendant Ghislaine Maxwell
Bennet J. Moskowitz, Esq.
Molly S. DiRago, Esq.
TROUTMAN SANDERS LLP
Tel:
Fax:
Email:
Counsel for Defendants Darren K. Indyke and Richard D. Kahn
By: /s/ Sigrid McCawley
Sigrid McCawley
3
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=== Page 1 ===
From:
To:
Subject: Accepted: Freddy Caraballo Proffer (re Epstein)
Date: Fri, 30 Aug 2019 17:41:43 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From: Public Policy Law360 <news@law360.com>
To:
Subject: Perkins Coie IP Atty Confirmed As Fed. Circ.'s 1st Black Judge
Date: Tue, 20 Jul 2021 08:06:52 +0000
Law3
60
PUBLIC POLICY
Public
Tuesday, July 20, 2021
Follow Law360
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Perkins Coie IP Atty Confirmed As Fed. Circ.'s 1st Black Judge
The Federal Circuit will see its first Black judge after a bipartisan Senate vote
Monday to confirm Tiffany P. Cunningham, a Perkins Coie LLP partner and
veteran patent litigator who said the appellate position had long been her
"dream job."
2 documents attached
Read full article
Contentious Biden Pick For 2nd Circ. Reports $1.3M Net Worth
A longtime voting rights litigator nominated to the Second Circuit whose efforts
to reduce voting barriers led to biting criticism from Senate Republicans has
reported a net worth of almost $1.3 million in congressional disclosures.
LAW FIRMS
Read full article »
Consumer Law Group
Arnold & Porter
Top Florida Litigation Of 2021: Midyear Report
Florida has seen no shortage of notable litigation developments in 2021,
Ballard Spahr
including a likely resolution of the state's long-running "Water Wars" with
Beasley Allen
Georgia and key rulings that could impact disputes arising from the COVID-19
Beck Reed
pandemic.
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Cohen Milstein
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Man Gets 18 Mos. For Murder Threats Against Flynn Judge
Foley & Lardner
A New York man was sentenced Monday to 18 months in prison after admitting
to threatening to assault and murder the D.C. federal judge who oversaw the
Foley Hoag
politically charged criminal case of former Trump national security adviser
Gibson Dunn
Michael Flynn.
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Congress Revives Push To Codify DOJ Access To Justice Unit
A powerful, bipartisan group in Congress is reviving a
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proposal to permanently restore the U.S. Department of Justice's Office for
Hunton Andrews
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for the poor that was shuttered by the Trump administration.
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BANKING & SECURITIES
Kuck Baxter
Robinhood Says It Expects $30M Fine From NY Regulator
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Robinhood said Monday that it now anticipates paying $30 million as part of a
Lewis Longman
tentative settlement with a New York regulator over anti-money laundering and
Lipcon Margulies
cybersecurity issues at its cryptocurrency subsidiary, double the amount that
McGuireWoods
the stock-trading platform previously earmarked for the matter.
Mintz Levin
Read full article
Morgan Lewis
Warren Calls For CFPB Scrutiny Of Overdraft Fees, Crypto
O'Melveny & Myers
EFTA00030767

=== Page 2 ===
Sen. Elizabeth Warren, D-Mass., said Monday that the Consumer Financial
Outten & Golden
Protection Bureau should be part of the regulatory response to emerging
Pentiuk Couvreur
cryptocurrency risks and cited "predatory" bank overdraft fee practices as an
Perkins Coie
area where she hopes to see action from the agency as it marks its 10th
Price Benowitz
anniversary.
Read full article
Rusty Hardin & Associates
ENERGY & ENVIRONMENTAL
Sidley Austin
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House Passes Bills To Tackle Energy Cybersecurity Threats
Sterlington PLLC
The U.S. House of Representatives on Monday approved a pair of legislative
Vinson & Elkins
proposals aimed at staving off cyber threats facing critical energy infrastructure
White & Case
in the wake of the damaging Colonial Pipeline hack by expanding the U.S.
Department of Energy's role in this realm and boosting information sharing
WilmerHale
between the government and industry.
COMPANIES
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Adobe Inc.
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Amazon.com Inc.
American Bar Association
Ex-FDA Senior Regulatory Counsel Joins Foley Hoag In DC
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Foley Hoag LLP has continued its growth in Washington, D.C., by adding a
American Federation of Labor &
former senior lead regulatory counsel from the U.S. Food and Drug
Congress of Industrial
Administration who spent nearly a decade with the agency, the firm announced
Organizations
Monday.
American Federation of State
Read full article
County & Municipal Employees
MEDIA & ENTERTAINMENT
Americans for Tax Reform
Apple Inc.
Garland's 'Historic' Leak Probe Memo Comes With Fine Print
Boston University
Attorney General Merrick Garland's move Monday to sharply curtail the seizure
Cable News Network Inc.
of data from reporters drew praise as a major step forward for press freedom,
Center for Justice
but experts say the memo leaves some wiggle room for the government to
snoop on sensitive news-gathering activities.
Center for Strategic and
International Studies
Memorandum attached Read full article
Cigna Corp.
Twitter Seeks 9th Circ. Review Of Texas' Moderation Probe
Colonial Pipeline Co.
Twitter lambasted a trial judge's denial of its lawsuit seeking to block Texas
DISH Network Corp.
Attorney General Ken Paxton's probe into the tech giant's moderation
DaVita Inc.
practices, telling the Ninth Circuit that it should revive the case because Paxton
DoorDash Inc.
is unlawfully retaliating against the company for removing former President
Donald Trump from the platform.
Dynamex, Inc.
Brief attached Read full article
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Facebook Inc.
GOP House Members Form 'Freedom From Big Tech' Caucus
Financial Industry Regulatory
A group of House Republicans launched a "Freedom from Big Tech Caucus,"
Authority Inc.
consisting of a group of conservative lawmakers who supported antitrust
GameStop Corp.
reform that advanced through the House Judiciary Committee last month.
Getty Images Inc.
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Google LLC
Major Networks Ask FCC To Clarify Advertisement ID Rules
GrubHub Inc.
The nation's largest broadcasters are asking the Federal Communications
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fall under the agency's newly passed rules on disclosure of advertisements by
Intel Corp.
foreign governments.
Comments attached Read full article
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Garland Urged To Bring Charges After Nassar FBI Report
Johnson & Johnson
Sen. Chuck Grassley, R-lowa, has asked Attorney General Merrick Garland to
Lockheed Martin Corp.
consider prosecuting the former president of USA Gymnastics and FBI agents
EFTA00030768

=== Page 3 ===
who allegedly made false statements to hide their botched investigation into
Los Angeles Times
team doctor Larry Nassar's pattern of sexual abuse.
Louisiana State Bar Association
2 documents attached Read full article
Massachusetts Institute of
DoorDash, Grubhub Sue San Francisco Over 15% Fee Cap
Technology
Delivery giants DoorDash and Grubhub hit San Francisco with a lawsuit in
McDonald's Corp.
California federal court Friday over a law permanently capping fees that the
Medicare Payment Advisory
platforms can charge local restaurants at 15%, arguing that the law violates the
Commission
U.S. and California constitutions and may unintentionally harm local
restaurants, workers and consumers.
Michigan State University
Complaint attached Read full article
Microsoft Corp.
Mississippi Center for Justice
Walmart Applicant Says Criminal Check System Discriminates
NBCUniversal Media LLC
A Brooklyn woman hit Walmart with a proposed class action in New Jersey
National Association for the
federal court on Monday alleging it unlawfully discriminates against applicants
Advancement of Colored People
with criminal backgrounds through broad screenings that don't consider
National Consumer Law Center
evidence of rehabilitation, a practice she says disproportionately harms Black
National Wildlife Federation
and Latino applicants.
Complaint attached Read full article
New York Post
New York University
COMPETITION
Norwegian Cruise Line
Analysis
Ohio State University
DaVita Indictment, Biden Order Ramp Up No-Poach Pressure
Orbit International Corporation
The U.S. Department of Justice and the Biden White House are making it
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abundantly clear to expect more criminal antitrust prosecutions against
Panasonic Corp.
employers that agree to control wages or avoid recruiting from one another.
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DOJ Says Wage-Fixing Charges Were Never Off The Table
Postmates Inc.
The U.S. Department of Justice told a Texas federal court that federal
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prosecutors never promised not to charge the former director of a physical
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therapist staffing company with criminal wage-fixing violations in exchange for
Space Exploration Technologies
his cooperation.
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State Bar of California
EU Watchdog Eyes Spain's €101M Investor Arbitration Award
Surgical Care Affiliates Inc.
Europe's competition watchdog is going to be taking a hard look at whether a
The Center for Immigration
€101 million ($119.2 million) arbitration award Spain has been ordered to pay
Studies
after it retracted economic incentives for renewable energy investment meshes
The New York Times Co.
with the bloc's state aid rules.
Twitter Inc.
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PERSONAL INJURY & MEDICAL MALPRACTICE
Uber Technologies Inc.
United States Olympic
Rioters Didn't Stop Congress On Jan. 6, Militia Says
Committee
The Oath Keepers militia group said Monday that members of Congress could
UnitedHealth Group Inc.
not sue over the Jan. 6 Capitol Hill riot because the lawmakers were the ones
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who interrupted the Electoral College certification with an emergency
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adjournment as rioters were attacking the Capitol.
Washington Post Co.
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INTERNATIONAL TRADE
GOVERNMENT AGENCIES
US And Vietnam Cool Trade Tensions With Currency Pact
Bureau of Citizenship and
Vietnam's central bank pledged to refrain from suppressing the value of its
Immigration Services
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administration Monday, quieting a long-simmering trade dispute between the
California Supreme Court
two nations.
Centers for Disease Control and
Read full article
Prevention
EFTA00030769

=== Page 4 ===
EU Fights Russia's 'Discriminatory' Import Policy At WTO
Centers for Medicare & Medicaid
The European Union launched a trade dispute with Russia at the World Trade
Services
Organization on Monday, saying that Russia's import substitution policy
Colorado Department of Labor
discriminates against foreign companies.
and Employment
1 document attached
Read
full
article
Consumer Financial Protection
Bureau
TAX
European Commission
Ghislaine Maxwell Owes NY $1.6M In Taxes, State Tax Dept. Says
European Union
Ghislaine Maxwell, former associate of deceased sex offender Jeffrey Epstein,
Federal Bureau of Investigation
is among the top 250 individual tax debtors in New York, owing nearly $1.6
Federal Communications
million, according to a list maintained by New York's tax department.
Commission
Memorandum attached Read full article
Federal Trade Commission
Florida Department of
Calif. Gov. Hopeful Threatens Suit Over Ballot Disqualification
Environmental Protection
A California candidate for governor said Monday that the secretary of state's
Food and Drug Administration
office disqualified him from the ballot because of improperly filed tax return
information and said he would sue if the decision wasn't reversed.
Government Accountability
Office
Letter attached Read full article
International Trade Commission
BANKRUPTCY
Legal Services Corp.
Massachusetts Supreme Judicial
Talc Plaintiffs' Attys Fume At Idea J&J Might Use Ch. 11 Tactic
Court
Attorneys representing talc injury plaintiffs in some of the thousands of lawsuits
National Aeronautics and Space
related to exposure to Johnson & Johnson products said Monday that the
Administration
company's purported plan to consider siloing its talc liabilities with a subsidiary
National Telecommunications
and then moving it into bankruptcy is shameful and should be barred by law.
and Information Administration
Read full article
New York State Department of
IMMIGRATION
Financial Services
New York State Department of
Feds Call Off Appeal Salvaging Trump-Era Asylum Guidelines
Taxation and Finance
The Biden administration has called off an appeal of a Washington, D.C.,
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federal judge's decision striking down Trump-era credible fear guidelines as
Reclamation and Enforcement
setting too high a hurdle for asylum-seekers to clear.
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Motion attached Read full article
U.S. Army
DC Judge Mulls Reserving Thousands More Diversity Visas
U.S. Army Corps of Engineers
A D.C. federal judge is apparently leaning toward ordering the U.S.
U.S. Attorney's Office
Department of State yet again to set aside thousands of visas for green card
U.S. Attorney's Office for the
lottery winners whom the federal government hasn't processed or interviewed
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by the time the visas are set to expire.
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U.S. Court of Appeals for the
Uber, Postmates AB 5 Suit Gets Nixed By Calif. Judge
Fifth Circuit
California escaped claims by Uber, Postmates and two drivers for those
U.S. Court of Appeals for the
companies that its worker classification test is unconstitutional after a federal
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judge agreed to toss the suit on the grounds that the law represents a
legitimate state interest.
U.S. Department of Commerce
Order attached Read full article
U.S. Department of Energy
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9th Circ. Backs DHS In Immigration Environmental Impact Row
Security
The Ninth Circuit nixed an appeal from conservationists and ranchers Monday,
U.S. Department of Justice
affirming that the U.S. Department of Homeland Security was not required to
U.S. Department of State
put immigration policies through environmental review.
U.S. Department of the Interior
Opinion attached
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U.S. District Court for the Central
ICE Pays $100K To End HIV-Positive Immigrant's Arrest Suit
District of California
U.S. Immigration and Customs Enforcement will pay an HIV-positive immigrant
U.S. District Court for the District
with a severe mental disability $100,000 to settle claims that he was
of Columbia
EFTA00030770

=== Page 5 ===
traumatized by an arrest that a New York federal judge described as "no
U.S. District Court for the District
routine" affair, according to a Monday court filing.
of New Jersey
1 document attached Read full article
U.S. District Court for the
NATIVE AMERICAN
Eastern District of Texas
U.S. District Court for the Middle
Oklahoma Sues DOI For Coal Control On Tribal Lands
District of Florida
Oklahoma has hit the U.S. Department of the Interior with claims that the
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department is threatening the coal industry by illegally taking away the state's
Northern District of California
authority over coal mining on Muscogee (Creek) Nation lands, teeing up a
U.S. District Court for the
major test of how the Supreme Court's landmark McGirt decision applies to
Northern District of Illinois
state regulation.
Complaint attached
Read full article
U.S. District Court for the
Southern District of Florida
TELECOMMUNICATIONS
U.S. District Court for the
Southern District of New York
Analysis
U.S. House Committee on
Broadband Sats Are Filling The Sky. Are Regulators Ready?
Energy and Commerce
When the FCC allowed SpaceX to shift its planned Starlink broadband satellite
U.S. House of Representatives
constellation closer to Earth in April, the approval may have seemed routine,
yet competitors like Dish and Viasat now say the unprecedented collection of
U.S. Immigration and Customs
Enforcement
devices could create challenges for scientific research and transmission from
their own satellites. Here's a look at the burgeoning industry and the policy
U.S. Securities and Exchange
questions still to be resolved.
Commission
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U.S. Senate
U.S. Supreme Court
CANNABIS
United States District Court for
the District of Colorado
Illinois Sued Over Revised Pot Biz Licensing Scheme
United States District Court for
Illinois' newly revised licensing scheme for pot businesses is unconstitutional,
the Western District of Oklahoma
an applicant has argued in a lawsuit alleging that a late change to the state's
social equity regime is unfair and that its "discrimination" against out-of-state
World Trade Organization
owners is a violation of the commerce clause.
Complaint attached Read full article
EXPERT ANALYSIS
Opinion
FTC Should Take Nuanced Approach On Noncompete Regs
In response to President Joe Biden's recent executive order encouraging the
Federal Trade Commission to regulate employer noncompete agreements, the
agency should approach potential rulemaking with restraint by focusing on fair
and transparent use of such agreements, says Russell Beck at Beck Reed.
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Colo. Equal Pay Law Is Raising Job Post Hurdles Nationwide
Because a compensation disclosure requirement in Colorado's new equal pay
law also applies to businesses outside of the state with potential to hire remote
workers who reside there, employers may want to consider several options to
avoid compromising their proprietary payment schemes or methodologies in
job ads, says Jonathan Israel at Foley & Lardner.
Read full article
FINRA Shows Subtle Shift On Evaluating Best Execution
McGuireWoods' Elizabeth Hogan and Alexander Madrid analyze the Financial
Industry Regulatory Authority's recent notice on best execution and payment
for order flow, identifying an isolated focus on price that pivots from prior
guidance emphasizing a more holistic approach.
Read full article
Questions To Ask After MedPAC Alternative Payments Report
EFTA00030771

=== Page 6 ===
The Medicare Payment Advisory Commission's recent report to Congress
recommends streamlining the number of alternative payment models with less
overlap to permit better evaluation of their success, but further detail is needed
on various issues, such as which aspects of different models actually result in
more savings and quicker payment, say attorneys at Foley & Lardner.
Read full article
Series
Embracing ESG: Cigna Counsel Talks Employee Wellness
Building employee well-being into corporate environmental, social and
governance priorities required our legal team to focus more closely on cross-
functional collaboration within the company and increased communication with
our board of directors and shareholders, says Julia Brncic at Cigna.
Read full article
LEGAL INDUSTRY
Girardi Warning Signs Slipped Through Legal Loopholes
Plaintiffs attorney Thomas V. Girardi escaped public discipline at the hands of
the State Bar of California many times over four decades as clients alleged he
stole millions of dollars from their settlements. How was he not held to
account? This is the first in a series of stories examining his alleged
misconduct and the system and culture that enabled it.
Read full article
Judge Sets Discovery Rules In Jones Day Family Leave Suit
A Washington, D.C., federal judge overseeing a suit by two former Jones Day
lawyers challenging the firm's parental leave policy has approved limits on who
can access sensitive information shared during discovery, but denied the ex-
associates' bid for a more expansive protective order.
Read full article
Must-Join Texas Bar Won't Fight Ruling That Limits Lobbying
The Texas bar association said Monday it will not fight a recent Fifth Circuit
finding that some of its legislative lobbying activities are "wholly disconnected"
from attorney regulation and unconstitutional for a mandatory-membership
state bar.
Read full article
BigLaw Partners Among New Crop Of Mass. ACLU Directors
The Massachusetts chapter of the American Civil Liberties Union and its
associated foundation have named a new slate of directors, including a former
jurist of the state's top court and several partners from BigLaw firms.
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=== Page 1 ===
From:
To:
Cc:
Subject: GM Whereabouts
Date: Mon, 22 Jun 2020 12:04:31 +0000
10-4, we have seen
-
On Jun 22, 2020 08:03
wrote:
FYI there is a press report this morning that she's hiding in Paris. No idea if it is accurate but wanted to flag for
you since it's of obvious concern.
https://www.the-sun.com/news/1014441/jeffrey-epstein-ghislaine-maxwell-hiding-paris-flat/
Sent from my iPhone
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=== Page 1 ===
From:
)"
To:
[Contractor]"
Subject: cover letter
Date: Mon, 02 Nov 2020 19:51:02 +0000
Attachments: 2020.11.02_Cover_Letter_to_PAE.docx
Cover letter to PAE attached, thank you!
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York. NY 10007
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=== Page 1 ===
From:
To:
Cc: Alex Conlon
, Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
Date: Fri, 13 Dec 2019 22:12:06 +0000
Attachments: Epstein_Proposed_VCP - DRAFT Protocol - 12.13.2019 - For_Distribution.pdf;
DS_Response_to_Creditor_Doe's_Motion_for_Extension_of_Time.pdf;
DS_Request_for_Immediate_Hearing_or_Conference_re_Claims_Program.pdf
Attached is the draft protocol we received from Feinberg and CO. Also attached are two documents the Estate filed in the
USVI today.
Kate
Kate L. Doniger I Kaplan Hecker & Fink LLP
From: Roberta Kaplan
Sent: Friday, December 13, 2019 4:53 PM
To:
>; Alex Conlon
Cc:
Subject: RE: Transcript from yesterday's conference
That is what Bennet Moskowitz said (I believe) at the earlier conference before M.J. Freeman
Alex: can you pls check the transcript? I know they have also said it to me directly and he certainly didn't disagree with
me when I said it before J Failla.
Also: we got the Feinberg draft protocol today; its exactly as much of a disaster as we expected.
Kate: psl send to
along with their recent VI filings.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
From:
Sent: Friday, December 13, 2019 1:09 PM
To: Alex Conlon
>; Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
This is helpful and interesting, thanks very much for sending. Among other things, notable that Judge Failla assumes, even
were punitive damages to be excluded, a claim "for millions upon millions of dollars."
Separately, Robbie, I noticed near the end of the conference you mentioned, at p. 27, that: "They [the estate and/or the
trustees?] have identified the sole beneficiary as Mr. Epstein's brother." I'm wondering if you might have a recollection of
what the estate has said or represented to you about that? And if you recall whether any discussion of beneficiaries was
in connection with the will versus the trust versus the estate, etc. Just if you feel comfortable sharing any of that
EFTA00030439

=== Page 2 ===
information, of course-no obligation at all. And if it's more convenient to relay in real time, rather than drafting up an
email, please don't hesitate to give a call. No emergency or rush, but did want to ask.
thanks,
From: Alex Conlon
Sent: Thursday, December 12, 2019 18:34
To:
Cc: Roberta Kaplan
Subject: Transcript from yesterday's conference
Hi there,
Attached is the transcript from yesterday's conference that Robbie described in the call today.
Take care,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
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.
EFTA00030440


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=== Page 1 ===
Event: Accepted: Meet re Epstein forfeiture
Start Date: 2019-12-09 19:00:00 +0000
End Date: 2019-12-09 20:00:00 +0000
Location:
office
Class: X-PERSONAL
Comment:
Date Created: 2019-12-04 22:46:45 +0000
Date Modified: 2019-12-04 22:46:45 +0000
Priority: 5
DTSTAMP: 2019-12-04 19:04:23 +0000
Attendee:
EFTA00029652


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
N
(USANYS)"
i
)"
)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
i
(USANYS) 1"
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 20:04:57 +0000
OK, thanks.
On Dec 31, 2020, at 3:00 PM,
(USANYS)
wrote:
Thanks
! We've incorporated your edits. As for you question about the "under investigation
language," the investigation related to the contraband cellphone is a matter of public record. As for
the
we've consulted with the MCC and softened that
,
language to the effect that Rivera was in the SHU for a disciplinary issue, without referencing the
specifics or the fact that
From:
(USANYS)
Sent: Thursday, December 31, 2020 2:09 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
i
)
is
)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
^
V.
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Apologies - I looked at this as soon as you sent it, but apparently my outlook was frozen and it was hanging in
cyberspace. I thought it looked good, although there were some typos which I fixed. I also had a couple of
questions/comments in one of the declarations (attached).
From:
(USANYS)
Sent: Thursday, December 31, 2020 12:19 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
i
(USANYS)
is
)
is
)
is
(USANYS)
^
Cc:
(USANYS)
>;
(USANYS)
i
(USANYS)
is
(USANYS)
EFTA00030058

=== Page 2 ===
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hi
:
Please see our proposed letter, which I understand you would like to review, as well as
declarations from associate wardens at the MDC and MCC. The GC and PC chiefs have signed off on
these drafts.
With apologies for the time sensitivity, our contacts at MCC/MDC have asked to leave early today
(before 1/1:30), and have asked us to finalize the declarations as soon as possible.
Best,
From:
(USANYS)
Sent: Wednesday, December 30, 2020 4:24 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
)
is
-
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
i
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
,
who is the Associate Warden at the MCC. There's a possibility that there will be a very
short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I
am working through that with
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:45 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
i
)
is
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks. Who is signing the declaration for BOP?
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
is
(USANYS)
V.
(USANYS)
is
(USANYS)
is
)
is
)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
i
(USANYS)
>;
(USANYS)
EFTA00030059

=== Page 3 ===
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
:
We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
explain that the discovery and counsel access accommodations that have been provided to Maxwell
and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of
their lawyers, and their individual housing circumstances. On all of these factors, there are several
important differences, including:
-
The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need
for such expanded discovery access is greater in the Maxwell case.
-
At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside
the general population. She therefore has sole access to a room to use a computer and phone
for approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
-
There are approximately 80 other inmates at the MCC in Rivera's unit that use the same VTC
room for court appearances, probation interviews, and attorney meetings. By contrast,
Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can
therefore provide 15 hours of VTC meetings with her attorneys without compromising access
for other MDC inmates. The same is not true for Rivera at the MCC.
Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day
long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same
amount of electronic discovery access to Rivera that Maxwell receives at the MDC.
As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
compromise access for other inmates. If defense counsel expresses a need for additional time, the
MCC will continue to find ways to accommodate those requests as best as they can.
Please let me know if you have any questions or would like to discuss this further.
Best,
From:
(USANYS)
Sent: Monday, December 21, 2020 4:42 PM
To:
(USANYS)
is
(USANYS)
i
(USANYS)
is
(USANYS)
i
is
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
^
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you
know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences
between MCC and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
i
(USANYS)
i
EFTA00030060

=== Page 4 ===
is
)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a
sex trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at
the MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was
originally scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had
new counsel appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which
requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a
videoconference order, which requires the MCC to make available four hours of videoconferencing
each week, in addition to any telephone or videoconference calls obtained through the Federal
Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time
Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation,
although defense counsel has stated that they may request more time in the future. However, in a
letter last night and during a court conference this morning (transcript attached), defense counsel
cited the accommodations that the MDC has provided to Maxwell, describing them as "strikingly
different and far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera
was being treated differently on account of his race, gender and class. Judge Engelmayer stated that
the disparity in access "jumped off the page" and that the optics were "terrible," and asked us to
explain the rationale for the differing treatment. After conferring with
and
before our conference, we explained our understanding that the disparity comes down to
the fact that Maxwell and Rivera have very different housing situations, with Maxwell's situation
being more amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to
Rivera. Based on the recent bail opposition in the Maxwell case, I believe the differences in
counsel/discovery access are as follows:
Accommodation
Maxwell
Rivera
EFTA00030061

=== Page 5 ===
Review of electronic
13 hours per day/7 days per
3 hours per day/7 days per
discovery (NB: each
week (91 hours total)
week (21 hours total)
defendant has laptop access)
Counsel visits (by video)
3 hours per day/5 days per
Four hours per week (plus an
week (15 hours total)
additional two hours
scheduled through the
Federal Defenders) (6 hours
total)
Weekend legal calls
As needed
Not available
The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
meantime, we are working with
to identify the appropriate declarant and draft an
explanation for the Court.
Best,
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
EFTA00030062


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=== Page 1 ===
From: "USANYS-InterpreterRequest"
To:
(USANYS)"
Subject: RE: Spanish Interpreter Needed for Proffers by
Date: Tue, 03 Sep 2019 16:40:30 +0000
Importance: Normal
is the interpreter for this meeting.
From:
(USANYS)
Sent: Friday, August 30, 2019 5:02 PM
To: USANYS-InterpreterRequest
Subject: Re: Spanish Interpreter Needed for Proffers by
Proffer at
On Aug 30, 2019, at 4:33 PM, USANYS-InterpreterRequest
wrote:
Is this a Proffer at
or a Grand Jury meeting at 40 Foley?
From:
(USANYS)
Sent: Thursday, August 29, 2019 9:19 AM
To: USANYS-InterpreterRequest
Subject: Spanish Interpreter Needed for Proffers by
AUSA:
AUSA Phone:
AUSA Cell Phone:
Contact Name (if not AUSA):
Contact Phone Number:
Language Needed:
Spanish
Case Name: In re Epstein Death Investigation
Proffers
Appointment Date:
Tuesday, September 3, 2019
Appointment Time:
2pm
Estimated Time Needed: 2 hours
Appointment Location: 40 Foley
Trial Date:
Additional Information :
Room 302.
EFTA00030561


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=== Page 1 ===
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EFTA00030217


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=== Page 1 ===
From:
To:
Subject: Re: Epstein Related
Date: Wed, 16 Oct 2019 17:50:21 +0000
No worries at all - I'm in Nashville for work through Friday morning but will be in the office on Friday
afternoon (and all next week), or also feel free to call my cell, either way.
Sent from my iPhone
On Oct 16, 2019, at 12:25,
wrote:
Sorry I didn't get time to circle back on this. Are you around late this afternoon (I'm second seating a trial that
goes until 4:30/5 but could find you after). Thanks
On Sep 15, 2019, at 11:27 AM,
wrote:
Sounds good.
From:
Sent: Sunday, September 15, 2019 09:15
To:
Subject: Re: Epstein Related
Let's chat tomorrow! I'm generally around and will look for you.
Sent from my iPhone
On Sep 14, 2019, at 7:09 PM,
wrote:
Hey I stopped by your office a couple times Thursday and Friday but didn't catch you, sorry about that -- I'm happy to
chat on Monday if you're around. My guess is that some combination of the press office and brass would make the
call, but I'm totally happy to touch base with you if that's useful in the first instance.
From:
Sent: Thursday, September 12, 2019 10:51
To:
Subject: Epstein Related
Do you have a few minutes today or tomorrow to discuss something? Specifically, a good friend of mine is the
executive producer on a 4-part Netflix series that will come out in a few months on Epstein (they had been working
on the story for 18 months before we charged). He had spoken to
at one point (not sure how that
worked!) and wants to see if anyone from the office would give an interview, all backward looking. I imagine the
answer is no but they are going with this regardless, so thought I would at least make you and potentially chiefs
aware of it. Wanted to start with you. I'm free between now and noon or after 6pm tonight, or tomorrow morning
or after lunch. Thanks!
EFTA00031457


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=== Page 1 ===
Event: Accepted: FBI / SDNY Epstein update mtg
Start Date: 2020-01-08 18:00:00 +0000
End Date: 2020-01-08 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-09 02:26:19 +0000
Date Modified: 2020-01-09 02:26:19 +0000
Priority: 5
DTSTAMP: 2020-01-06 23:06:57 +0000
Attendee:
EFTA00031825


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=== Page 1 ===
From:
"
)"
To:
"
)"
Subject: RE: message for
Date: Thu, 02 Jan 2020 19:10:00 +0000
-
01/02/19, left another message
From:
Sent: Monday, December 30, 2019 14:20
To:
Subject: message for
-
12/30/19, left a message with receptionist for
re: Epstein case
Assistant U.S. Attorney
Southern District of New York
EFTA00030752


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Memos
Date: Thu, 09 Apr 2020 14:52:11 +0000
Attachments: Geoff_Notes_Potential_Perjury_by_Maxwell.docx
Thanks, that works for the team. In case it's helpful, I'm attaching the list you sent us of Geoff's excerpts, so that
nobody needs to search for it.
Original Message
From:
Sent: Thursday, April 9, 2020 10:36 AM
To
Cc
Subject: Re: Memos
Could you do a little earlier, maybe around 330?
Sent from my iPhone
> On Apr 9, 2020, at 10:27 AM,
wrote:
>
> To add to this, on the Maxwell memo, one issue we've been struggling with is how to address the comments on
the perjury section, and that issue isn't straightforward. We think it would be helpful to have a call to talk through
the perjury issue-- would it be possible to have a call later today, perhaps around 5?
>
> Thanks--
>
V
V
Original Message
> From
> Sent: Thursday. April 9. 2020 10:05 AM
To:
> Cc
> Subject: RE: Memos
V
> We circulated updates to both memos internally last night, and we're all hoping to be able to both provide and
incorporate comments to the respective drafts today, with the goal of getting you updates later today as well. We
should preview that both memos have expanded considerably based on the comments and suggestions, so it may
be helpful to do an additional turn once you're able to review so we're sending up the best (and not unnecessarily
rushed) products it would give everybody some breathing room, I think, if we aimed for very polished final
versions early next week. But if you both have very few comments on the next rounds, they likely could get
pushed up as early as tomorrow.
V
V
EFTA00031573

=== Page 2 ===
>
Original Message
> From:
> Sent: Thursday, April 09, 2020 08:51
> To:
> Cc
> Subject: Memos
V
> Hey guys,
>
> Do you think you will get either of the memos to us today? Would be great to review one of them so that we
can get it to the brass tomorrow while the other is finished up.
>
> Thanks,
>
V
> Sent from my iPhone
EFTA00031574


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: Fwd: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Mon, 18 Oct 2021 21:54:06 +0000
Attachments: Response_to_Govt_voir_dire_opposition.pdf
FYI
Begin forwarded message:
From: BOBBI C STERNHEIM
Date: October 18, 2021 at 5:50:52 PM EDT
To:
)"
(USANYS)"
)"
=
,
)"
Cc: Christian Everdell
>, Laura Menninger
, Jeff
Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
New York, NY 10007
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00031205

=== Page 2 ===
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=== Page 1 ===
From:
)"
To:
Subject: Accepted: Epstein Call
Date: Thu, 21 May 2020 13:35:08 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
U.S. ATTORNEY GEOFFREY S. BERMAN
FOR IMMEDIATE RELEASE
CONTACT: U.S. ATTORNEY'S OFFICE
Monday, July 8, 2019
http://www.justice.gov/usao/nys
NYPD
FBI
JEFFREY EPSTEIN CHARGED IN MANHATTAN FEDERAL COURT
WITH SEX TRAFFICKING OF MINORS
Alleged Conduct Occurred in both New York and Florida over Multiple Years,
Involving Dozens of Victims
Geoffrey S. Berman, the United States Attorney for the Southern District of New York,
, the Assistant Director in Charge of the New York Field Office of the
Federal Bureau of Investigation ("FBI"), and
Commissioner of the New York
,
City Police Department ("NYPD"), announced that JEFFREY EPSTEIN was arrested Saturday
and charged with sex trafficking of minors and conspiracy to commit sex trafficking of minors.
The indictment unsealed today alleges that, between 2002 through 2005, EPSTEIN sexually
exploited and abused dozens of underage girls by enticing them to engage in sex acts with him in
exchange for money. Epstein allegedly worked with several employees and associates to ensure
that he had a steady supply of minor victims to abuse, and paid several of those victims
themselves to recruit other underage girls to engage in similar sex acts for money. He committed
these offenses in locations including New York, New York, and Palm Beach, Florida. EPSTEIN
is expected to be presented in Manhattan federal court this afternoon before U.S. Magistrate
Judge Henry B. Pitman. The case is assigned to U.S. District Judge Richard M. Berman.
U.S. Attorney Geoffrey S. Berman said: "As alleged, Jeffrey Epstein abused underage
girls for years, operating a scheme in which girls he victimized would recruit others for Epstein
to exploit and abuse. Epstein exploited girls who were vulnerable to abuse, enticed them with
cash payments, and escalated his conduct to include sex acts, often occurring at his residence on
the Upper East Side of Manhattan. While the charged conduct is from a number of years ago,
the victims - then children and now young women - are no less entitled to their day in court.
My Office is proud to stand up for these victims by bringing this indictment."
EFTA00029813

=== Page 2 ===
FBI Assistant Director
said: "We are asking anyone who may
have been victimized by Jeffrey Epstein, or anyone who may have information about his alleged
criminal behavior, to please call us. The number is 1-800-CALL-FBI. We want to hear from
you, regardless of the age you are now, or whatever age you were then, no matter where the
incident took place. The bravery it takes to call us might empower others to speak out about the
crimes committed against them. It is important to remember there was never, nor will there ever
be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come
first."
NYPD Commissioner
said: "Today's charges serve as a warning to
individuals who continue to prey upon some of our society's most vulnerable population: we are
coming for you. I thank and commend the U.S. Attorney's Office for the Southern District and
the FBI for their tireless efforts to ensure child predators are taken off our streets. The NYPD
will continue to work with our law enforcement partners to eradicate the trafficking of children
in our city and nation and work to bring justice to victims of these heinous crimes."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein,
please contact the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 2002 through at least 2005, JEFFREY EPSTEIN enticed and recruited, and
caused to be enticed and recruited, dozens of minor girls to visit his mansion in New York, New
York (the "New York Residence"), and his estate in Palm Beach, Florida (the "Palm Beach
Residence"), to engage in sex acts with him, after which he would give the victims hundreds of
dollars in cash. In order to maintain and increase his supply of victims, EPSTEIN also paid
certain victims to recruit additional underage girls whom he could similarly abuse. In this way,
EPSTEIN created a vast network of underage victims for him to sexually exploit, often on a
daily basis, in locations including New York and Palm Beach.
EPSTEIN's victims were as young as 14 at the time he abused them, and were, for
various reasons, often particularly vulnerable to exploitation. Moreover, EPSTEIN knew that
many of his victims were under 18, including because, in some instances, victims expressly told
him they were underage.
In creating and maintaining this network of minor victims in multiple states to abuse and
exploit sexually, EPSTEIN worked with others, including employees and associates who
facilitated his conduct by, among other things, contacting victims and scheduling their sexual
encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.
In both New York and Florida, EPSTEIN perpetuated this abuse in similar ways.
Victims were initially recruited to provide "massages" to EPSTEIN, which became increasingly
sexual in nature and would typically include one or more sex acts. EPSTEIN paid his victims
hundreds of dollars in cash for each encounter.
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.
EFTA00029814

=== Page 3 ===
In particular, during encounters at the New York Residence, victims would be taken to a
room where they would perform a massage on EPSTEIN, during which EPSTEIN would
frequently escalate the nature and scope of physical contact with his victims to include, among
other things, sex acts such as groping and direct and indirect contact with the victims' genitals.
In connection with the encounters, EPSTEIN, or one of his employees or associates, typically
paid each victim hundreds of dollars in cash. Once minor victims were recruited, EPSTEIN or
his employees or associates would contact victims to schedule appointments for "massages." As
a result, many victims were abused by EPSTEIN on multiple subsequent occasions.
To further enable him to abuse underage girls, EPSTEIN asked and enticed certain of his
victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts
with EPSTEIN. When a victim would recruit another underage girl for EPSTEIN, he paid both
the victim-recruiter and the new victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN maintained a steady supply of new victims to exploit, and gained access to
dozens of additional underage girls to abuse.
*
JEFFREY EPSTEIN, 66, is charged with one count of sex trafficking of minors, which
carries a maximum sentence of 40 years in prison, and one count of conspiracy to engage in sex
trafficking of minors, which carries a maximum sentence of five years in prison.
The statutory maximum and mandatory 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.
Mr. Berman praised the outstanding investigative work of the FBI and the NYPD. He
also thanked the U.S. Customs and Border Protection for their assistance.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
Attorneys
are in charge of the prosecution,
with assistance from the Office's Human Trafficking Co-Coordinator,
The charges contained in the Indictment are merely accusations. The defendant is
presumed innocent unless and until proven guilty.
19-211
###
EFTA00029815


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=== Page 1 ===
From:
To:
)"
Subject: Emailing: WOLSEN_20200630164003652_DRAFT.pdf
Date: Tue, 30 Jun 2020 20:47:14 +0000
Attachments: WOLSEN_20200630164003652_DRAFT.pdf
I am working on getting the docket number off the letter.
How does it look. Do you want to add the paragraph the FBI sent us.
EFTA00031859


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=== Page 1 ===
From: Christian Everdell
To: ⑉
Cc:
Bec: "USAHUB-USAJournal111"
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion and Exhibits (to be Filed
Under Seal)
Date: Tue, 08 Dec 2020 22:22:47 +0000
Embedded: U.S._v._Ghislaine_Maxwell,_20_Cr._330_(AJN)_-- --
_Renewed_Bail_Motion_and_Exhibits_(to_be_Filed_Under_Seal).msg
Sender:
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion and Exhibits (to be Filed Under
Seal)
Message-Id: <92d93e4f92644d0580f1c9e6199a5f64@CohenGresser.com>
Recipient:
EFTA00030755


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: ISO response to defense calling many, many agents
Date: Wed, 24 Nov 2021 21:23:00 +0000
Attachments: Government_MIL_[final,_unredacted].pdf; Govt_Reply_Brief_[unredacted].pdf;
2021.11.01_Final_pretrial_conference.PDF
Sorry for the delay! Attached is our MIL briefing, which include sections seeking to preclude the defense from attacking
the investigation. AJN's ruling on the issue is on pages 15 through 30 of the attached transcript.
From:
Sent: Wednesday, November 24, 2021 11:10 AM
To:
Cc:
Subject: RE: ISO response to defense calling many, many agents
Amazing, thanks!
From:
Sent: Wednesday, November 24, 2021 11:09 AM
To
Subject: Re: ISO response to defense calling many, many agents
We've been dealing with this in Maxwell. We have some briefing and a decent oral ruling from Judge Nathan on this. Will
send when I'm at my desk.
On Nov 24, 2021, at 11:02 AM
wrote:
Good morning all,
Anyone have briefing in response to defense counsel's efforts to call at trial numerous (here, 7) agents involved in the
investigation, to varying degrees, in an effort to impeach the investigation? Something maybe akin to - you can't put the
investigation on trial.
(They've provided a Touhy letter, so not looking for that).
Thank you!
EFTA00031115


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Supplemental Pretrial Motions,
Reply Memorandum (to be Filed Under Seal)
Date: Fri, 28 May 2021 23:39:21 +0000
Attachments: 2021.5.28_Cover_Letter_to_Judge_Nathan_re_Supplemental_Pretrial_Reply_Motion.PDF;
Reply_Memorandum_ISO_Supplemental_Pretrial_Motions_FINAL.PDF
Inline-Images: image005.jpg; image006.jpg
FYI
From: Christian Everdell
Sent: Friday, May 28, 2021 5:44 PM
To: 'Nathan NYSD Chambers'
Cc:
)
is
>;
(USANYS)
is
)
>; 'BOBBI C STERNHEIM'
; 'Jeff Pagliuca'
>; 'Laura Menninger'
Subject: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Supplemental Pretrial Motions, Reply Memorandum (to be Filed
Under Seal)
Dear Judge Nathan -
As set forth in the attached cover letter and pursuant to Rule 2(B) of the Court's individual rules, attached for the Court
and government are copies of Ms. Maxwell's Omnibus Reply Memorandum in Support of Her Supplemental Pretrial
Motions Related to the S2 Superseding Indictment. The cover letter is being filed on the public docket.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
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.
EFTA00031906


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Re: Epstein Bail Letter
Date: Wed, 10 Jul 2019 01:01:51 +0000
Importance: Normal
Thank you!!!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
On Jul 9, 2019, at 8:22 PM,
)
wrote:
Here you go!
From:
(USANYS)
Sent: Tuesday, July 9, 2019 4:44 PM
To:
)
Subject: Epstein Bail Letter
Could you send me a word doc of you bail letter in Epstein? I am preparing a written detention app based on risk of
flight and would love to crib some of your case law/rhetoric. Thanks!!!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
<2019-07-08, JE, detention memo, final.docx>
EFTA00030830


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
)"
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 19:44:58 +0000
Attachments: 2021-10-15_GM_letter_re_MDC_legal_mail_Final.docx
and
signed off on the letter. Attaching what we plan to file.
From:
(USANYS)
Sent: Friday, October 15, 2021 2:04 PM
To:
(USANYS)
Cc:
(USANYS)
is
>;
is
Subject: Re: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Ah-I see the highlights now. Agree.
Sent from my iPhone
On Oct 15, 2021, at 1:49 PM,
(USANYS)
wrote:
I think this is good but would delete the highlighted sentences. I agree with not engaging on footnote.
Sent from my iPhone
On Oct 15, 2021, at 1:29 PM,
(USANYS)
wrote:
Attached is a draft response due today at 5 pm. We still need to send this letter to
and
at the
MDC to review for accuracy. Do you think you will be able to review shortly or should I send them this draft
simultaneously? We highlighted some language for your consideration about Judge Nathan's deadlines, happy to
discuss. We haven't engaged with the defense's footnote 1 about the volume of the materials delivered because that
is a little more complicated and we want to make sure any representations are fully accurate, but happy to discuss.
Thanks,
From:
(USANYS)
Sent: Friday, October 15, 2021 10:30 AM
To:
)
is
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
EFTA00031202

=== Page 2 ===
Thanks. (We've really got to talk to Nathan about these deadlines!)
From:
)
Sent: Friday, October 15, 2021 10:30 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Cc:
is
;
)
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Hi
/
Judge Nathan just ordered us to respond to this letter as soon as possible but no later than 5 pm today. We've
reached out to BOP to set up a call.
Thanks,
From:
(USANYS)
Sent: Thursday, October 14, 2021 8:31 PM
To:
(USANYS)
>;
(USANYS)
Cc:
is
in
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
FYI, letter filed by Bobbi Sternheim tonight.
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
Sent: Thursday, October 14, 2021 7:46 PM
To:
is
(USANYS)
is
is
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good evening-
Attached is a courtesy copy of this evening's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
New York, NY 10007
EFTA00031203

=== Page 3 ===
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.
<2021-10-15 GM letter re MDC legal mail v2 [to chiefs].docx>
<Ltr to Ct re Legal Mail 10-14-21.pdf>
EFTA00031204


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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Location: 877-720-9282 - 8146826
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 13:51:30 +0000
Date Modified: 2020-05-21 13:51:30 +0000
Priority: 5
DTSTAMP: 2020-05-21 13:35:07 +0000
Attendee:
EFTA00030784


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Subject: pros memo examples
Date: Wed, 17 Jun 2020 21:11:44 +0000
Attachments: 2020-04-10_GM_prosecution_memo.pdf; 2019-06-17,_JE_prosecution_memo.docx
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031508


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=== Page 1 ===
From:
=
(USANYS)"
To:
(USANYS) [Contractor]"
i
(USANYS)"
Subject: Call/Meeting on Epstein
Date: Fri, 07 Dec 2018 02:48:11 +0000
Importance: Normal
Attachments: unnamed
EFTA00029655


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=== Page 1 ===
From:
Bcc: "USAHUB-USAJournal111"
Subject: RE: 3 more devices for review
Date: Wed, 28 Oct 2020 13:02:19 +0000
Embedded: RE:_3_more_devices_for_review.msg
Sender:
Subject: RE: 3 more devices for review
Message-Id:
<SN5P110MB04629DE6DA61ED8292B55A90ED170@SN5P110MB0462.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00030566


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=== 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 17:51:31 +0000
Inline-Images: image001.png
Well done sir
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
EFTA00031326

=== 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.
EFTA00031327

=== 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.
EFTA00031328


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=== Page 1 ===
July 13, 2021
Prep (by VTC)
AUSAs
&
SA
Det.
Prepared for trial testimony. Clarified the following:
Although
cannot recall every piece of evidence he seized, he specifically recalls
seizing message pads and twin torpedoes sex toy from 358 El Brillo Way on October 20,
2005.
Photographs of message pads and twin torpedoes from the scene are fair and accurate
depictions of portions of 358 El Brillo Way as they appeared on October 20, 2005.
All evidence, including message pads and twin torpedoes, was turned over to the
evidence collection team, which was supervised by Crime Scene Manager
Crime scene team then transported all evidence to PBPD.
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: FW: SDNY COIVD Screening Forms for next week
Date: Fri, 13 Aug 2021 21:54:29 +0000
Attachments:
-Fact_Witness_Travel_Request.docx
Hi
Please see below. Would you be able to send the hotel confirmation for
please? I'm reattaching the
travel request for reference. You sent me his flight confirmation, but did not include a hotel.
Thanks,
Original Message
From: Giffuni, Danielle
Sent: Friday, August 13, 2021 5:53 PM
To:
Cc: McGorty, Glen
>; Zelenko, Daniel
)
(USANYS)
)
Subject: Re: SDNY COIVD Screening Forms for next week
has not received confirmation of his hotel or the location. Can you advise? Thanks.
Best,
Danielle
Sent from my iPhone
On Aug 13, 2021, at 5:27 PM,
wrote:
External Email
2pm is fine on our end, thanks very much. See you then.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: McGorty, Glen
Sent: Friday, August 13, 2021 5:08 PM
EFTA00031450

=== Page 2 ===
To:
Zelenko, Daniel
Giffuni, Danielle
Cc:
Subject: RE: SDNY COIVD Screening Forms for next week
Danielle and I are going to be covering Monday's in-person meeting with Mr.
and we look forward to
seeing everyone. On scheduling, I've had a few other commitments come up which make 1 p.m. challenging.
Would a 2 p.m. start work on your end? Please let me know.
Best,
Glen
Glen G. McGorty | Crowell & Moring LLP
Managing Partner, New York Office
590 Madison Avenue | 20th Floor | New York, NY 10022-2524
<mailto:
I
https://protect2.fireeye.com/v1/url?k=66c54f25-
395e77f7-66c26bc0-0cc47adc5fdc-e9bcfe6b773546e6&q=1&e=28033cda-5860-4cae-8f98-
6e4eaf859586&u=http%3A%2F%2Fwww.crowell.com%2F<https://protect2.fireeye.com/v1/url?k=2360369b-
7cfb0e49-2367127e-0cc47adc5fdc-d61411b10ea2bc44&q=1&e=28033cda-5860-4cae-8898-
6e4eaf859586&u=https3A%2F%2Furldefense.proofpoint.com%2Fv2%2Furl%3Fu93Dhttps-
A_protect2.fireeye.com_v1_url-3Fk-3D2092029e-2D7f093a62-2D2095267b-2Dac1f6b01771c-
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From:
)
<mailto:
Sent: Friday, August 13, 2021 3:34 PM
To: McGorty, Glen
<mailto:
Zelenko, Daniel
<mailto:
Giffuni, Danielle
<mailto:
Cc:
)
<mailto:
>;
EFTA00031451

=== Page 3 ===
(USANYS)
<mailto:
)
<mailto:
Subject: SDNY COIVD Screening Forms for next week
External Email
Hi all,
In advance of our meeting(s) with Mr.
at 1 St. Andrews, we'll need to ask everyone who is attending,
including your client, to please fill out the attached form. Would you please send me the completed forms in
advance of our meeting?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
EFTA00031452


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: FW: Discovery Issues
Date: Mon, 29 Mar 2021 19:23:48 +0000
Attachments: SDNY_Production_Issues_20210329.xlsx; SlipsheetExample-SDNY_GM_00541380.pdf
Inline-Images: image002.jpg; image004.jpg
Hey
Would you please take a look at number 7 below, and let me know what the response is?
Thanks,
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
EFTA00029942

=== Page 2 ===
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY_GM_SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
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
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EFTA00029943


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10621156 has received final approval
Date: Fri, 13 Sep 2019 02:20:58 +0000
Importance: Normal
Dear
Travel authorization 10621156 has received final approval.
Trip ID: 10621156
Traveler name
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R19NYS13832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-09 - 2019-09-10
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0006
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00031354


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Automatic reply: Epstein Estate Touhy Requests
Date: Tue, 20 Aug 2019 18:20:34 +0000
Hello,
I am in Dallas for depositions, through Friday, August 23, 2019.
is covering.
Thanks,
EFTA00030966


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=== Page 1 ===
From:
"
)"
To:
)"
)"
=
Subject: Epstein discovery deadline
Date: Wed, 31 Jul 2019 16:01:58 +0000
Importance: Normal
Attachments: unnamed
EFTA00030514


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=== Page 1 ===
From:
Subject: SW
Date: Fri, 05 Jul 2019 15:40:57 +0000
Importance: Normal
Attachments: 2019.07.05_New_York_Residence_SW.pdf
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00030175


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: out of curiosity
Date: Thu, 09 Apr 2020 14:19:43 +0000
Yeah suddenly an AMI pros memo became very urgent last week.
On Apr 9, 2020, at 10:12 AM,
wrote:
To the extent anybody in this small group is willing to share, are any of you folks' teams / cases getting significant
pressure from the chiefs on memos or other written product this week, whether for the brass or otherwise? I'm just
curious whether it's just the Epstein case (where we're getting near-daily prodding about imminent deadlines for
memos that are both extremely time-intensive and also couldn't possibly be acted upon for weeks, given the
circumstances of the world) or if it's something broader in the unit. I just sent the chiefs a pretty crabby email about
being bugged daily about lengthy, detailed work product and it made me wonder whether this is a trend or an isolated
incident.
More importantly, hope y'all and families are all staying healthy
Assistant U.S. Attorney
Southern District of New York
EFTA00031092


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=== Page 1 ===
From:
To:
Subject: Epstein Image/Video File Review Protocol
Date: Mon, 19 Oct 2020 21:50:54 +0000
Importance: Normal
Attachments: unnamed
Dial-in:
Pin:
EFTA00030603


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From:
)"
To:
)"
)"
Subject: Fwd: detention memo
Date: Tue, 30 Jun 2020 22:59:04 +0000
Attachments: 2019-06-29_GM_detention_memo.ebd.docx; ATT00001.htm
I'll turn to this now- any other comments before it goes up the chain? Thanks.
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: June 30, 2020 at 6:46:24 PM EDT
To:
)"
Cc:
)"
)"
Subject: RE: detention memo
Thanks very much,
This is persuasive - I read this, and I think we might have a real shot at detention. My
comments and suggestions in track. Can you take a look, and unless there's stuff to discuss, can you send the next draft
to the Brass, and feel free to note if you want that it is still rough/in the works, but that in the interests of giving
everyone a chance to weigh in on the substance, in particular, we wanted to circulate sooner rather than later.
From:
Sent: Tuesday, June 30, 2020 3:48 PM
To:
(USANYS)
Cc:
is
Subject: detention memo
Hi
Attached is a draft of the memo - there may be more edits from the team, so l'll incorporate their edits along with yours
later on. Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031850


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Nader
Date: Sat, 17 Apr 2021 15:23:53 +0000
Attachments: Maxwell_Opinion.pdf
Hi
Just wanted to say thanks again for speaking with me about the Nader case. After extensive briefing, we received a
favorable opinion in our case yesterday, which I'm attaching in case you're curious.
Thanks very much-
From:
Sent: Thursday, February 11, 2021 3:32 PM
To:
Subject: RE: United States V. Nader
Great to hear the brief was helpful! You can reach me at 757-395-9043 if now is a good time to chat. Otherwise let me
know and we can set up a time whenever is convenient.
From:
Sent: Wednesday, February 10, 2021 9:45 PM
To:
Subject: United States V. Nader
Hi
I'm an AUSA in the Southern District of New York, and I'm currently briefing a retroactivity issue that I believe you litigated
in United States V. Nader, 19 Cr. 201 (LMB). I've read your brief in that case, and it was very helpful. Do you happen to
have a few minutes this week for a brief call? It would be helpful to get your perspective on the issue, after having
litigated it successfully.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031422


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Date: Fri, 12 Mar 2021 16:08:21 +0000
You're welcome to join, and I'm adding you to the calendar invitation, but certainly no need, I can deal with this one.
From:
Sent: Friday, March 12, 2021 11:05 AM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Yes, so far I'm free Monday a.m. pick a time and send a Webex
From:
Sent: Friday, March 12, 2021 10:57 AM
To:
Cc:
is
(USANYS)
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Hi
Thanks for your guidance on this. Are you available for a follow-up call on Monday? I'm free before 10:30, if you have time
in the morning.
Thanks,
From:
Sent: Thursday. March 11. 2021 10:56 AM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
I've had several dealings with
who is pretty responsive. I don't recall having had many dealings with the
other EOUSA FOIA attorneys
lists.
From:
Sent: Thursday, March 11, 2021 10:54 AM
To:
is
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
The following EOUSA AUSAs are involved:
I also direct access
to my counterpart in SFL for those cases.
EFTA00030080

=== Page 2 ===
FOIA Office
Ph:
Cell
From:
Sent: Wednesday, March 10, 2021 5:44 PM
To:
Cc:
>;
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Oh, sorry: our FOIA Tracking Database is designed to cover FOIA requests that are directed to our Office; it
does not track FOIA requests to, e.g., the FBI, that end up in litigation in the SDNY and that our Civ Div
defends.
From:
Sent: Wednesday, March 10, 2021 5:40 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Thanks,
could you please check your records and let us know if there are any other cases? From
's list, it
seems like at least one case is missing (there is a civil case involving a FOIA request from Radar Online).
From:
Sent: Wednesday, March 10, 2021 5:23 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
As we just discussed:
Here is what we have in our FOIA tracking database regarding Epstein FOIAs.
And also attached is the letter in PPI about discovery vs FOIA (see p. 8)
From:
Sent: Wednesday, March 10, 2021 5:20 PM
To:
Cc:
is
>;
Subject: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Hi
Hope you're doing well.
and
and I are trying to assemble a list of every FOIA request our office has ever
received (at any point) relating to Jeffrey Epstein and/or Ghislaine Maxwell.
suggested that you'd be the
best point of contact to help us figure this out. Could you please send us the following information:
A list of all FOIA requests our office has received;
For each case, whether a production was made in response to the request; and
Who the AUSA point of contact for the request is.
That would be a big help. Please let us know if you need any information from us to run the search.
EFTA00030081

=== Page 3 ===
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
"
)"
To:
(NY) (FBI)"
Subject: FW: Signed warrant
Date: Mon, 29 Jun 2020 21:38:15 +0000
Attachments: Application_for_Maxwell_GPS_Combo.pdf; Maxwell_arrest_warrant_signed.pdf
You'll need to pull the warrants from the PDF, but they're attached. Thanks!
From:
Sent: Monday, June 29, 2020 5:36 PM
To:
Subject: Fwd: Signed warrant
Get Outlook for iOS
From: KHP_Warrants NYSD
Sent: Monday, June 29, 2020 5:31:08 PM
To:
Cc:
Subject: Fw: Signed warrant
From:
Sent: Monday, June 29, 2020 8:56 PM
To:
>; Arraignment NYSD
Cc:
>; KHP_Warrants NYSD
Subject: Signed warrant
Get Outlook for iOS
EFTA00030346


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=== Page 1 ===
From: Jack Scarola
Cc: "Chris R. Rodgers"
Subject: RE Request for information
Date: Sat, 13 Feb 2021 19:55:50 +0000
Inline-Images: RE_Request_for_information.png
For whatever help, if any, it may be, this is a picture of
taken at about the time of her abuse by Epstein.
Her recollection is that two photos of her were taken while she was topless. Obviously, copies of those photos
would be of critical importance if they were ever recovered.
EFTA00030893

=== Page 2 ===

=== Page 3 ===
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.
EFTA00030895


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=== Page 1 ===
From:
To:
Subject: RE: Bail orders
Date: Wed, 25 Mar 2020 19:11:00 +0000
Attachments: 2020-03-XX_-_Letter_Opposing_Bail_v2.docx
This is what I filed with Buchwald that led to the Order
circulated a little while ago. It responded to, what I have
been calling, the defense-circulated boilerplate "airing of grievances" about BOP.
From:
Sent: Wednesday, March 25, 2020 3:06 PM
To:
Subject: RE: Bail orders
All -
I am guessing everyone is getting inundated with these. If possible, could people reply all with the word version
of what they've been submitting? I am assuming that the requests fall in the following categories:
1. Boilerplate request (i.e., pretrial detention and defendant has no risk factors)
2. Pretrial detention with certain risk factors (heart condition; asthma, etc.)
3. Post plea, pre-sentence
4. Post sentence
I am attaching one I did in a post sentence case. The defendant has to go through BOP process before applying
to the court for compassionate release. I am also attaching two from a gang case (one defendant had diabetes
and the other was more general). These were filed before the confirmed MCC case. With respect to the diabetic
defendant, Judge Daniels just denied the order without an opinion.
But, as we are handling many of these, it would be helpful to see what others are arguing.
Hope everyone is doing well!
From:
Sent: Wednesday, March 25, 2020 2:54 PM
To:
Subject: Bail orders
Attached is an order issued by Judge Engelmayer last week in a bail appeal. To the extent we end up consenting to bail or
a judge orders bail, this order is a helpful example.
Also attached is an order from Judge Buchwald denying bail where defense raises the boilerplate COVID-19 argument
we've been seeing in some cases. This could be helpful as we see more and more of these filed.
Assistant United States Attorney
EFTA00031506

=== Page 2 ===
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
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From:
(USANYS)"
To:
)"
)"
)"
Cc:
(USANYS)"
Subject: RE: Filing today
Date: Thu, 13 Aug 2020 20:33:42 +0000
Okay, thanks. Phew.
Original Message
From:
)
Sent: Thursday, August 13, 2020 4:33 PM
To:
(USANYS)
i
Cc:
(USANYS)
Subject: RE: Filing today
Nope, just today ("by Thursday")
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 16:30
To:
)
i
Cc:
(USANYS)
Subject: FW: Filing today
This isn't due at 5, is it?
Original Message
From: Margolin, James (USANYS) [Contractor]
Sent: Thursday, August 13, 2020 4:29 PM
To:
)
(USANYS)
(USANYS)
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
(USANYS)
Subject: Filing today
I understand you're supposed to be filing a response today (by 5:00?) to a defense motion to have Maxwell
released to the general population at MDC, or at least to be detained under conditions they say would allow her
greater access to a computer and the opportunity to review discovery materials? Main (OPA) is keenly interested
because of the AG's response last summer to Epstein's suicide and his bow to overhaul BOP and ensure inmate
safety, so a guy down there asked if we could send him what you file as soon as you do. (Apparently the AG is
getting questions from Congressional Republicans about what's being done to ensure Maxwell's safety.)
James Margolin
Chief Public Information Officer
EFTA00030430

=== Page 2 ===
U.S. Attorney's Office, SDNY
(office)
(cell)
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From:
To:
)"
Cc:
Subject: RE: Brunel
Date: Tue, 12 Jan 2021 15:01:16 +0000
Thanks
We can use the following:
From:
Sent: Tuesday, January 12, 2021 9:55 AM
To:
is
is
Cc:
Subject: RE: Brunel
Sure, I can do 11am.
Let me know what # to call.
U.S. Embassy, Paris
From:
Sent: Tuesday, January 12, 2021 3:36 PM
To:
i
is
Cc:
Subject: RE: Brunel
Thanks very much,
Do you have a few minutes to speak today about this? I'm available after 11 am EST.
From:
Sent: Tuesday, January 12, 2021 6:11 AM
To:
i
is
Cc:
Subject: RE: Brunel
Here are my comments.
U.S. Embassy, Paris
EFTA00030842

=== Page 2 ===
From:
Sent: Friday, January 8, 2021 7:32 PM
To:
is
^
is
Cc:
Subject: RE: Brunel
Hi
Thanks again for the update and all of your help. Attached please find our MLAT request. Please let us know if you have
any questions or would like to discuss.
Best,
From:
Sent: Thursday, January 07, 2021 11:12 PM
To:
in
is
Cc:
Subject: RE: Brunel
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Thursday, January 7, 2021 5:17 PM
To:
is
is
Cc:
Subject: Brunel
Dear all:
EFTA00030843

=== Page 3 ===
My meeting on Brunel went well this afternoon. Here is the quick read out:
EFTA00030844

=== Page 4 ===
U.S. Embassy, Paris
From:
Sent: Thursday, January 7, 2021 12:38 AM
To:
is
is
Cc:
Subject: RE: France
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, January 6, 2021 10:15 AM
To:
is
is
Cc:
Subject: RE: France
Further to our call yesterday, here are the points I plan to make at my meeting tomorrow. Thanks in advance for letting me
know if you see any errors, omissions, or additions to make:
EFTA00030845

=== Page 5 ===
U.S. Embassy, Paris
From:
Sent: Tuesday, January 5, 2021 9:02 PM
To:
is
>;
Cc:
Subject: France
Here is our go-by for an outgoing request to France.
U.S. Embassy, Paris
EFTA00030846


c1: EFTA00031611
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031611.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
)"
Subject: RE: Quick Epstein FOIA question
Date: Sun, 02 May 2021 16:59:15 +0000
Thanks!
From
Sent:
PM
To: Kd
Cc:
Subject: Re: Quick Epstein FOIA question
I'm ok with it
On May 2, 2021, at 11:47, Kochevar, Steven (USANYS)
wrote:
Hi.
The attached got marked as a Tartaglione withheld in full, but I don't think that's right. This can be released with no
Tartaglione concerns, right?
Thanks,
<Pages from 19-0556 New York Times - Epstein Records Unmasking Remaining WIF #2-A (050121 845 pm).pdf>
EFTA00031611


c1: EFTA00029866
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029866.pdf
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c7: images
c0:
=== Page 1 ===
July 12, 2021
t Prep
AUSAs
&
SA
Det.
Prepared for trial testimony.
previously undisclosed, clarifying, or different recollections
below:
believes
was about 16 years old when she invited
to JE's house.
After
first time going to JE's house with
estimates that
went to
,
JE's house approximately once or twice a month for about two months, then went
biweekly and then weekly.
When
was dating
had a job, so he did not spend every minute with
estimates that
would have between $200 and $300 after each massage at JE's
house
cannot identify the specific origin of the accent belonging to the woman other than
who called his phone to schedule appointments for
to see JE. Indicated it was
European but does not think it was French.
does not recall
being addicted to cocaine or crack when they were dating.
believes
lied to
when they were dating about where she was at different times
and about her fidelity to him in their relationship.
currently uses marijuana every day for anxiety.
EFTA00029866


c1: EFTA00030720
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030720.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Joe Nascimento
To:
)"
Cc:
)"
"
)"
Subject: Re:
)
- Epstein
Date: Tue, 10 Sep 2019 12:32:15 +0000
Great, see you there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on Okeechobee Blvd.
My cell is
when you arrive. My colleague,
will be joining us, and he can be
reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
EFTA00030720

=== Page 2 ===
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
>
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
>;
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or 13th work
best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this afternoon. I'll
plan to reach out then to discuss scheduling, if that's okay.
Thanks,
EFTA00030721

=== Page 3 ===
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check in to see if you still planned to travel south given the storm. Current estimates show
a landing (somewhere) Tuesday with very bad weather on Wednesday. Airports might close (which will
answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a hotel in West
Palm Beach, and l'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
>;
Subject: Re:
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
EFTA00030722

=== Page 4 ===
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on September 4th.
We're flexible on timing that day, but we would propose meeting at 12:30 p.m., if that works.
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon (anytime
after 1)? I have proactive cooperation ongoing in another case involving multiple jurisdictions, and they are
looking to meet the morning of 8/14. I understand if your schedule is already set, and will work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
EFTA00030723

=== Page 5 ===
)"
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and we'll follow
up to firm up plans as we get closer. If there are any conflicts with that date, please let us know, we're happy
to be flexible.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I do not have any travel plans during the month of August, nor does
September is a busy month with
two trials set, and I will be traveling out of the country from Sept 17-30, but I will do everything to be as
flexible as possible.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00030724

=== Page 6 ===
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
) - Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you could please
let us know if there are any particular weeks that would not work for you or your client for a meeting in
Florida (in particular, we don't want to interfere with anyone's summer vacation plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it would be
helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
>;
Subject: Re:
)
- Epstein
Hi
,
That works for me. Please call me on my cell
Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're available on
Friday at 2:30, if that works, but let us know if there are other times that would be more convenient for you.
EFTA00030725

=== Page 7 ===
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
As always, feel free to contact me at any time if we can be of further assistance. Look forward to meeting
again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
i
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are here, and
we will meet you in the lobby.
Thanks,
EFTA00030726

=== Page 8 ===
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating logistics,
and we will let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any reason:
-
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
EFTA00030727

=== Page 9 ===
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. B<x-apple-data-detectors:/2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors:.//2/0>
<x-apple-data-detectors.//2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors:.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com http//www.crimlawfirm.com -http:/www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
)
mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
EFTA00030728

=== Page 10 ===
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
mailto:
Subject: Re:
)
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-apple-data-
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors.//2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http//www.crimlawfirm.com><http:/www.crimlawfirm.com/>
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com>http://www.crimlawfirm.com
From:
)"
<mailto:
EFTA00030729

=== Page 11 ===
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on Tuesday
- you can reach us at
,
or we can also call you then if that's easier, whatever you
prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time
for Tuesday morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
EFTA00030730

=== Page 12 ===
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 7, 2019, at 4:04 PM,
)
mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect
our schedules may be somewhat unpredictable tomorrow; would it work to set a time to talk on
Tuesday? We can schedule it for before you meet with
,
if that's helpful. Or if you'd like
to talk sooner, we could schedule a time later today, or check in tomorrow about a possible
afternoon discussion. Please let us know what you prefer, and we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
mailto:
Subject:
)
- Epstein
My former partner, Alan Ross, represented
,
prior to his
passing in 2018. Agent
served
with a grand jury subpoena earlier today, and
as Alan's former partner and FL Bar appointed inventory attorney, she has contacted me.
Unfortunately, I am unable to meet with her until Tuesday, but I would appreciate a few minutes of
your time at your convenience as I am getting up to speed. Please let me know what day/time is
best for you.
Look forward to speaking with you.
EFTA00030731

=== Page 13 ===
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<x-apple-data-detectors:/2/0>rd<x-apple-data-detectors/2/0> Avenue<x-apple-data-
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http//www.crimlawfirm.com><http:/www.crimlawfirm.com/
EFTA00030732


c1: EFTA00029939
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
"Weinstein, Marc A."
Cc:
Subject: RE: following up
Date: Fri, 09 Apr 2021 14:29:28 +0000
Marc and Andy,
I'm writing to ask for one point of clarification regarding the estate's position regarding the assertion of attorney-client
privilege. You previously conveyed to us that the estate asserted privilege with respect to devices the FBI seized from
Jeffrey Epstein's residences in New York and the USVI in 2019. We accordingly assembled a firewall team to conduct a
privilege review of the contents of those devices.
The FBI is also in possession of a computer that the Palm Beach Police Department seized from Epstein's residence in Palm
Beach in 2005, which our office has not reviewed. Is the estate also asserting privilege with respect to devices such as this
one that were seized in Florida in 2005?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, March 31, 2021 1:59 PM
To: Weinstein, Marc A.
is
Cc:
is
Subject: RE: following up
Thanks, talk to you then. We can use this conference line:
From: Weinstein, Marc A.
Sent: Wednesday, March 31, 2021 1:52 PM
To:
is
Cc:
>;
Subject: RE: following up
3:30 works for us.
EFTA00029939

=== Page 2 ===
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor
New York
NY 10004-1482
Office
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, March 31, 2021 1:35 PM
To: Weinstein, Marc A.
is
Cc:
is
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Thanks very much- - would it be possible to speak slightly later on Monday, perhaps at 3:30 or later? Alternatively, we're
available between 10:30 and 2 p.m. on Monday.
From: Weinstein, Marc A.
Sent: Wednesday, March 31, 2021 10:58 AM
To:
is
Cc:
is
Subject: RE: following up
how about Monday at 2:30pm?
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor
New York
NY
10004-1482
Office
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, March 31, 2021 9:33 AM
To:
Weinstein, Marc A.
Cc:
is
Subject: following up
EFTA00029940

=== Page 3 ===
CAUTION: This email was sent by someone outside of the Firm.
Marc and Andy,
Hope you're both doing well. Are you available for a call early next week? We wanted to follow up with you on an aspect
of our previous document requests.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029941


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c0:
=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Mon, 06 Jul 2020 19:41:01 +0000
Inline-Images: image001.png
Hey thank you - really appreciate it! And I hope you're doing alright these days!!
From
Sent: Thursday, July 02, 2020 14:46
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Awesome work.
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO TOTAL UNITED
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
STATES
OF
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
EFTA00031501

=== Page 2 ===
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
EFTA00031502

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
*
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
EFTA00031503

=== Page 4 ===
unless and until proven guilty.
EFTA00031504


c1: EFTA00030341
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030341.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al.,
SDNY Case No. 1:20-cv-00484-JGK-DCF
Date: Tue, 30 Jun 2020 20:25:32 +0000
No problem! Good luck with everything. I don't think there's any hard deadline on the request because we're not in court
and they didn't send a subpoena. So the main constraint is Glassman's annoyance. I wrote him a brief note back last night,
although I doubt that will keep him happy for very long. I try not to provide specific timelines on stuff like this, but if we
need too much more time I can try letting him know a more specific sense of timing. Thanks!
From:
Sent: Tuesday, June 30, 2020 1:38 PM
To:
Subject: RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case No.
1:20-cv-00484-JGK-DCF
Hey I apologize for the delay - our entire team has been absolutely swamped for the past two weeks; we indicted
Ghislaine Maxwell yesterday and now are working on arrest plans, and it's been insane. I very much hope to be able to
take care of this next week, it's just been one thing after another for a little while.
From:
Sent: Sunday, June 28, 2020 23:06
To:
Subject: Fwd: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case No.
1:20-cv-00484-JGK-DCF
Hi
Just checking in on this-do you think it will be possible to gather the materials this week? I will write Glassman back and
tell him that I hope to follow up soon.
Thanks,
Sent from my iPhone
Begin forwarded message:
From: Robert Glassman
Date: June 26, 2020 at 12:49:19 AM EDT
To:
(USANYS)"
Cc:
>, "Nathan Werksman"
>, Keilah Betts
Subject: Re: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case
No. 1:20-cv-00484-JGK-DCF
Mr.
I am following up on my client's request. It would mean a lot for your office to do what it can to see that
her request is complied with in an expedient manner. Thank you.
EFTA00030341

=== Page 2 ===
Robert S. Glassman
Panish Shea & Boyle
psblaw.com
On Jun 8, 2020, at 4:19 PM,
(USANYS)
wrote:
Dear Mr. Glassman,
Thank you for your letter. I will follow up.
Thanks,
From: Robert Glassman
Sent: Monday, June 8, 2020 3:08 PM
To:
Cc:
>; Nathan Werksman
>; Keilah
Betts
Subject: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe V. Indyke et al., SDNY Case No.
1:20-cv-00484-JGK-DCF
Importance: High
Dear Mr.
Please see the attached letter of today's date. A copy will also be sent via Fedex. Thank you.
Robert Glassman
Robert Glassman, Esq.
Panish Shea & Boyle LLP
Los Angeles, CA 90025
Email:
Web: www.psblaw.com
CONFIDENTIALITY NOTICE:
This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use,
distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to
the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you
have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other
deadlines for your case or potential case.
EFTA00030342


c1: EFTA00030437
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030437.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10892303 approved by
, now awaiting further
approval
Date: Fri, 13 Dec 2019 01:07:11 +0000
Importance: Normal
Dear
Travel authorization 10892303 has been approved by
, now awaiting further approval.
Trip ID: 10892303
Traveler name:
Purpose: R20NYS13197 - U.S. V. Epstein - Witness Interview (California)
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-17
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
E2 Manual Login (User ID and Password):
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00030437


c1: EFTA00031616
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031616.pdf
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c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein T&E Meeting
Start Date: 2020-01-10 16:30:00 +0000
End Date: 2020-01-10 17:30:00 +0000
Location:
Office
Class: X-PERSONAL
Comment:
Date Created: 2020-01-09 03:08:17 +0000
Date Modified: 2020-01-09 03:08:17 +0000
Priority: 5
DTSTAMP: 2020-01-08 23:39:25 +0000
Attendee:
EFTA00031616


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c0:
=== Page 1 ===
From:
To:
Cc:
Bec:
Subject: bail opinion
Date: Thu, 31 Dec 2020 03:33:11 +0000
Embedded: bail_opinion.msg
Sender:
Subject: bail opinion
Message-Id:
<BN3P110MB033941988C7B0274E9DCD26B92D60@BN3P110MB0339.NAMP110.PROD.OUTLOOK.CO
M>
Cc:
EFTA00030056


c1: EFTA00031488
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031488.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:27:58 +0000
Inline-Images: image001.png
Thanks man!!
Fron
Sent: Thursday, July 02, 2020 13:25
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00031488

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00031489

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00031490


c1: EFTA00029704
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029704.pdf
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c7: images
c0:
=== Page 1 ===
From:
To: Bruce Barket
Cc: Aida Leisenring
Subject: Re: MCC
Date: Tue, 03 Mar 2020 18:17:57 +0000
We are still producing inmates for court.
>>> Bruce Barket
3/3/2020 12:50 PM >>>
I understand that MCC has been on lockdown for a week. Leaving aside for the moment the inhumanity of keeping inmates
locked in a cell 24/7 for that long, are they going to allow Nick to appear in Court tomorrow?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City. NY 11530
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
EFTA00029704


c1: EFTA00029861
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029861.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
)"
=
)"
i
)"
(USANYS)"
(USANYS)"
111
,
(USANYS)"
Cc:
)"
i
)"
=
Subject: RE: draft press release
Date: Tue, 30 Jun 2020 21:25:20 +0000
Attachments: 2020-06-30,_GM,_press_release,_draft.docx
Team,
Attached is a draft press release for the Maxwell arrest - hopefully for tomorrow or Thursday at the latest. Happy to
incorporate any edits.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00029861


c1: EFTA00029778
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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029778.pdf
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c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
(USANYS) [Contractor]"
(NY) (FBI)"
i
)"
Cc:
(USANYS)"
(NY) (FBI)"
)"
)"
(USANYS)"
(NY) (FBI)"
Subject: RE: Epstein search warrant documents
Date: Fri, 19 Jun 2020 17:20:13 +0000
can comment on the status of the hard drives. Also,
is going to expedite getting copies of
Epstein's phone and tablet seized during his arrest to the team so their review can be a priority.
SSA
FBI New York
On Jun 19, 2020 1:14 PM,
(NY) (FBI)"
wrote:
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
is
is
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
EFTA00029778

=== Page 2 ===
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
>;
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
EFTA00029779

=== Page 3 ===
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
The four San Disk cruzer-thumbdrives (NYC024344-47)
EFTA00029780

=== Page 4 ===
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00029781

=== Page 5 ===
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
EFTA00029782

=== Page 6 ===
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
>;
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.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
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.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
EFTA00029783

=== Page 7 ===
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
)
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
-
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
EFTA00029784

=== Page 8 ===
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
V.
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
EFTA00029785

=== Page 9 ===
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
is
i
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
EFTA00029786

=== Page 10 ===
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
i
is
(NY)
(FBI)
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.
EFTA00029787

=== Page 11 ===
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
EFTA00029788

=== Page 12 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
in
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
EFTA00029789

=== Page 13 ===
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
EFTA00029790

=== Page 14 ===
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
EFTA00029791


c1: EFTA00030961
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030961.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>
Cc:
)"
Subject: Discovery and Disclosure Practices -- Update
Date: Fri, 04 Dec 2020 16:50:46 +0000
All:
Over the last several months, the executive staff has been giving a great deal of thought to ways in which we can enhance
the Office's effectiveness in satisfying our discovery and disclosure obligations. Although that process is continuing, I want
to provide you with an update about some measures that we are implementing immediately, based on feedback we
received from you and your unit chiefs.
First, I am pleased to announce that we will maintain a standing Disclosure Committee to help the Office navigate our
discovery and disclosure challenges on an ongoing basis. The Disclosure Committee will be led by co-chair
and its members will be
Second, we have enlisted a Technology Working Group to evaluate possible approaches to improving our technological
and administrative support for your work, in close consultation with
and our IT staff. That group is led by
and its members are
Third, we recognize that the substantive work of each unit may present particular discovery challenges. To ensure that
AUSAs are familiar with the particular issues that may arise with respect to the work of a particular unit, unit chiefs will
provide training for new AUSAs who arrive in their unit as part of the onboarding process, with an emphasis on the
subject-matter-specific discovery and disclosure issues that they are likely to encounter as part of the unit's work.
Fourth, in advance of charging senior unit cases, AUSAs will conduct agency case file reviews to ensure we have full
visibility on material subject to disclosure-and are not relying solely on agents to surface materials subject to disclosure.
While this will not be required in all junior unit cases, agency file reviews should be conducted in General Crimes and
Narcotics cases where unit chiefs deem it appropriate. The Disclosure Committee will be overseeing the development of
agency-specific checklists to help facilitate the review, but in the meantime AUSAs should use their best judgment.
Fifth, prosecution memos must contain a robust discussion of discovery issues and defense theories as a pre-requisite for
approval by chiefs in the first instance and ultimately deputy chief signoff. The Disclosure Committee will be developing
guidance for areas that should be covered-but, in the meantime, AUSAs and chiefs should use their best judgment.
Sixth, when AUSAs leave senior units they will discuss case transition planning with the unit chiefs and the Criminal Chief,
and memorialize the case transition planning in a memorandum addressing the status of all of their cases and specifying
which cases they will be retaining and which will be reassigned. These memos will require approval by both the old and
new unit chiefs and will be reviewed by the Criminal Chief.
Seventh, in those rare instances when SAUSAs are approved for a particular case, they will complete all DOJ discovery
training requirements and SDNY disclosure training as part of their onboarding process before they can begin work as a
SAUSA. We will require certification of the completion of all required training as part of the SAUSA onboarding process.
The Criminal Division Manual will be revised to reflect this policy.
Some of these practices are already being followed by some units and some AUSAs. Going forward, they will be the
practice of the entire Office. We hope that these practices, amplified by the forthcoming guidance from the Disclosure
Committee, will provide AUSAs with useful tools and better position us to discharge our disclosure obligations.
As always, we welcome and appreciate your feedback. If you have thoughts or suggestions about how these practices are
working, or these issues generally, please share them with your unit chiefs, any member of the Disclosure Committee or
Technology Working Group, or the executive staff.
EFTA00030961


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: FW: Epstein Sharing Order Part II
Date: Mon, 29 Jun 2020 20:02:01 +0000
Attachments: 2019.12.19_Epstein_6(e)_App_Order_JMM.docx.
Remember way back in late January/early February when we got a second sharing order so we could send all of the trust
agreements over to Civ Div? From emails I know it was signed on 2/4 but can't seem to find the actual signed order. Do
you by any chance have it?
From:
(USANYS)
Sent: Friday, January 31, 2020 11:43 AM
To:
>;
(USANYS)
Cc:
>;
Subject: RE: Epstein Sharing Order Part II
OK, I made some idiosyncratic changes, plus a few things highlighted in green for you to verify. I have one Q set
forth in the footnote.
From:
Sent: Friday, January 31, 2020 11:29 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
is out, but the clerk's office says to use the same miscellaneous number because the applications are related. The
prior misc number was: 19 Misc. 0586
And attached for reference in case that's helpful.
From:
(USANYS)
Sent: Friday, January 31, 2020 10:32
To:
(USANYS)
is
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Working on it right now.
please check with
to see if we should use the same docket no as was
assigned to the first 6e order.
From:
(USANYS)
Sent: Friday, January 31, 2020 9:54 AM
To:
>;
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Great, thanks for catching.
let us know if you have any comments/thoughts. Thanks
EFTA00031886

=== Page 2 ===
From:
Sent: Friday, January 31, 2020 9:53 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Yes, this looks good, thanks - I made one more typo correction in the attached (in the new Trust Two language, "and
revocations" got repeated in the footnote and the order) but otherwise no changes.
From:
(USANYS)
Sent: Friday, January 31, 2020 09:48
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part II
Thanks for flagging,
I made a few small changes (which I highlighted since we've got a fair bit of track already) which
I think should make this broad enough to cover the Trust Il stuff. Can you take a quick look and if everyone is okay with
this, perhaps we can plan to get this to CM on Monday morning? Thanks
From:
Sent: Thursday, January 30, 2020 7:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
I apologize for the delay on this - I've added the relevant language about revocations to both the application and the
order, and corrected a stray typo, so that stuff is good to go. But two quick things to note, not to belabor this, but - it
doesn't look like there's any reference to the Trust Two documents - that may be because they're not referenced in any
will? At a glance I don't see Trust Two in any of the wills, but I'd want to go back and look more thoroughly unless
somebody already made the decision on that basis. And second, it references a 2019 Trust but I don't see any documents
on that? I have to run out tonight but can certainly circle up with
and/or
tomorrow on any of this, or just ignore
it if I've misread.
thanks,
From:
(USANYS)
Sent: Thursday, January 30, 2020 12:05
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
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
EFTA00031887

=== Page 3 ===
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
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,
EFTA00031888


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10643456 approved by
now awaiting further
approval
Date: Thu, 12 Sep 2019 20:43:37 +0000
Importance: Normal
Dear
Travel authorization 10643456 has been approved by
now awaiting further approval.
Trip ID: 10643456
Traveler name
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Los Angeles, CA, United States
Dates: 2019-09-17 - 2019-09-20
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00031353


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: PAE and Litigation priorities
Date: Wed, 14 Oct 2020 14:25:58 +0000
The PAE issue of case prioritization seems to be getting worse and we wanted to get your thoughts. The
was put on the priority list back in September but the team is
unfortunately now back to getting the answer from PAE/database managers that there are only 2 priority cases that is
taking up all of the PAE resources, Epstein and 377 Union Street. The
team sent search warrant returns to PAE on
9/22 and followed up yesterday to see if there was any ETA on getting them loaded and were told no. I completely
understand that not all jobs can be a rush job but am hopeful that we can find a way for some of the PAE bandwidth to be
reserved to load data in the normal course. If there could be a set expectation in terms of a timeline by which PAE is
expected to load data in the normal course, I think that would be helpful guidance for us to provide to our unit so they
can plan accordingly.
Happy to discuss.
Thanks,
From:
Sent: Friday, September 11, 2020 1:47 PM
To:
Subject: Fwd: PAE and Litigation priorities
Another
Sent from my iPad
Begin forwarded message:
From:
Date: August 28. 2020 at 10:24:45 AM EDT
To:
Subject: Re: PAE and Litigation priorities
Yes, of course.
On Aug 28, 2020, at 10:02 AM,
wrote:
Can we chat on Monday. PAE is looking to us to help them set priorities. As you can see
has hounded them and
now 377 Union Street is their number one priority.
also hounds them. Between the two, they monopolize
IT/Litigation Support to the detriment of other AUSAs.
Sorry to bother you on vacation. Hope it has been restful.
From:
Sent: Friday, August 28, 2020 9:31 AM
EFTA00031095

=== Page 2 ===
To
Cc
Subject: RE: PAE
just met with
and in addition to the priorities listed below, we have an number of other cases that are hot as
well. Currently 377 Union is the priority PAE is working on due to a proposed September production date set by the
AUSA. Due to the data size and complexity, other requests are still being worked on by in a limit capacity mode. Grisel
will reach out to PAE to get a sense of when they can address
request.
Also, are you available Monday morning to chat about PAE, requests and the updates to the meeting we held with the
SDNY working committee.
PAE also mentioned there are other "hot" cases they're working on:
1. We Build the Wall
Data must be processed and
uploaded to Relativity asap to begin privilege review
2. Epstein
Data must be
processed and uploaded to Relativity asap to begin privilege review
3. PPI
AUSA mentioned to SDNY PM there's a
court deadline.
4. Keefe V US FDA
court deadline to produce every 25th of the month
5. US V Jain
allegedly a deadline
to produce by August 28th
6. 377 Union Street: 5 HDs of mixed data. Duplicate data, issues with load files, data disorganized
From:
Sent: Thursday, August 27, 2020 2:59 PM
To
Subject: RE: PAE
Or starting them.
From:
Sent: Thursday, August 27, 2020 2:59 PM
To:
Subject: RE: PAE
Well, she's always putting out fires
From
Sent: Thursday, August 27, 2020 2:54 PM
To
Subject: FW: PAE
It is always a fire drill with her. Always
will have
call PAE tomorrow to determine if there is a problem
there or here.
Ed
From:
Sent: Thursday, August 27, 2020 2:52 PM
To:
Cc
Subject: PAE
PAE is taking much longer to respond to my requests to move potentially privileged documents out of databases;
weeks instead of days, which is affecting the ability of AUSAs to access their evidence in a number of investigations
and prosecutions. Do you know what is causing the delays? And how long it is expected to continue? And if there is
any way that I can assist, please let me know.
Thanks
Assistant United States Attorney
Southern District of New York
One St. Andrews Plaza, Room 929
EFTA00031096

=== Page 3 ===
New York, NY 10007
EFTA00031097


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=== Page 1 ===
From:
"
)"
To: "
(USANYS)"
Cc: "
)"
Bcc: "USAHUB-USAJournal111"
Subject: Re: SDNY case
Date: Sat, 12 Dec 2020 16:41:02 +0000
Embedded: Re:_SDNY_case.msg
Sender:
Subject: Re: SDNY case
Message-Id: <A9BDE55A-F5D1-43BA-B779-9DD2C68A2CAD@usa.doj.gov>
To:
Cc:
EFTA00031732


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Fwd: Jeffrey Epstein
Date: Sun, 07 Jul 2019 20:38:43 +0000
Importance: Normal
Congrats again!
Begin forwarded message:
From:
(USANYS)"
Date: July 7, 2019 at 1:08:19 PM EDT
To:
Cc:
)"
)"
(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.
&
EFTA00030172


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=== Page 1 ===
Event: Epstein Image/Video File Review Protocol
Start Date: 2020-10-20 17:00:00 +0000
End Date: 2020-10-20 17:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2020-10-20 04:39:48 +0000
Date Modified: 2020-10-20 04:39:48 +0000
Priority: 5
DTSTAMP: 2020-10-19 21:50:51 +0000
Attendee:
is
(USANYS)
Alarm: Display the following message 15m before start
Reminder
Dial-in:
Pin:
EFTA00030604


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=== Page 1 ===
From:
)"
To:
)"
Subject: Re: Maxwell/Epstein VNS
Date: Mon, 12 Apr 2021 19:35:45 +0000
Thanks!!
Sent from my iPhone
> On Apr 12, 2021, at 1:32 PM,
)
wrote:
>
> Sure
will send it to you
V
> Sent from my iPhone
V
>> On Apr 12, 2021, at 3:03 PM,
)
wrote:
Hi
>> Are you able to send us the current contact list for the VNS system for this case? We wanted to take a look at
the contact information.
>> Thanks, and hope you're doing well!
>> Sent from my iPhone
EFTA00031425


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=== Page 1 ===
From:
Subject: Accepted: Meet re: Epstein
Date: Tue, 02 Apr 2019 17:25:01 +0000
Importance: Normal
Attachments: unnamed
EFTA00030265


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=== Page 1 ===
TIME OFF AWARD
Presented to
Michael A. Thomas
Materials Handler Supervisor
in recognition of your commitment to the goals of Correctional Services
you are being rewarded with a sixteen (16) hour time off award.
METROPOLITAN CORRECTIONAL CENTER
New York, New York
Maureen P. Baird, Warden
June 12, 2015
EFTA00031448


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=== Page 1 ===
From:
To:
Subject: PPT
Date: Thu, 15 Aug 2019 13:28:17 +0000
Attachments: 2019.08.14_Brass_Presentation_PPT_v3.pptx
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00029715


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:13:28 +0000
Inline-Images: image001.png
Thank you!!
From:
Sent: Thursday, July 02, 2020 13:27
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats, guys — amazing work!!!
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00030381

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00030382

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00030383


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: RE: travel invoices / comp time (California trip, Nov. 13-15)
Date: Mon, 18 Nov 2019 21:07:32 +0000
Attachments: 2019-11-13,_California_comp_time.pdf
Following up on my trip to California last week, I've just dropped off receipts for expenses, including the hotel invoice and
three taxi receipts for airport trips. Please note that because I unfortunately forgot my work card, ALL the charges are to
my personal credit card. It's five receipts total, which are:
1) 11/13, taxi to JFK Airport, $ 59.33 (Uber, personal credit card)
2) 11/13, taxi from airport to hotel, $ 56.46 (taxi, personal credit card)
3) 11/15, hotel invoice, $ 573.12 (personal credit card)
4) 11/15, taxi from hotel to airport, $ 19.34 (Uber, personal credit card)
5) 11/15, taxi from JFK Airport to home, 61.56 (taxi, personal credit card)
Separately, my comp time form is also attached.
Please let me know if any questions or issues at all, and thanks very much!
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Monday, November 18, 2019 09:37
To:
Subject: Please Send Me Your Hotel Invoice & Any Taxi Receipts for Trip to Los Angeles, CA from 11/13 - 11/15/19
Importance: High
Good morning
Please send me your hotel invoice and any taxi receipts you may have for your trip to Los Angeles, CA from 11/13
-11/15/19. I'll need them to fill out your Travel Claim Form for reimbursement. Thanks as always!
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
EFTA00030426


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=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B10
Evidence Item: 31E-MM-108062 - 1B10
Evidence Type: General
Description: (U//FOUO) One red rope: ONE (1) BOOK-MASSAGE FOR DUMMIES
Location:
E03707388 - ECR8
E616844 ECR8, VS33
E5448596 - ECR8, VS33 A
Barcode:
E6516712
Details
Collected On: 08/07/2007 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2007-08-07
Collected From: (U//FOUO)
2210 48TH TERRACE NORTH
WEST PALM BEACH, FL,
Receipt Given:
No
Holding Office: MM - MIAMI
Evidence Log: Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
SDNY_GM_02753585
EFTA00029928

=== Page 2 ===
FD-1004
FEDERAL BUREAU OF INVESTIGATION
Revised
9-25-2006
EVIDENCE CHAIN-OF-CUSTODY
Evidence Type:
General
Drug
Valuable
Firearms
CART
Special Handling Instructions
Initial Receipt
Date and
Time
Batteries
Biohazard
FGJ
Signature:
HAZMAT
Latents
Refrigerate
8/7/07
Req. Charging
None
Printed Nam
Other
Reason: Conected
11:WA
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signatu
02/08/2008
Printed
Reason
10:00m
Date and
Time
Signatu
2-08-08
Printed
330PM
Reason
Date and
Time
Signature
04/10/2008
Printed
Reason
11:01am
Date and
Time
Signature
1-13-09
Printed
314PM
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name:
6/14/14
Printed Name:
Reason:
Reason:
Firearms Certification:
Printed Name:
Signature:
Date:
Case ID: 31E-MM-148062 1B:
10
Barcode: 54229237
E6516722
SDNY_GM_02753586
EFTA00029929

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody
Date and Accented.Custody
Date and
Time
Signa
Printe
9/20/19
Reaso
11
3:00pm
Relin
Date and
Time
Signat
Printe
6/24/19
Reaso
daile
Relin
Date and
Time
Signat
Printe
9/26/19
Reaso
22op
Relin
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 10
Barcode: 14829837 E6516712
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753587
EFTA00029930

=== Page 4 ===
FD-597 (Rev 8-11-94)
Page 1 of /
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File # 31E-mm-108062-1810
On (date)
08/07/2007
item(s) listed below were:
X
Received From
Returned To
Released To
Seized
(Name)
(Street Address)
(City)
Description of Item(s): 1) Book- MASSAGE FOR DUMMIES
Received
Received Fro
SDNY_GM_02753588
EFTA00029931


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030096.pdf
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=== Page 1 ===
From:
)"
To:
Subject: Read: Question re Epstein Relativity
Date: Mon, 15 Mar 2021 18:27:09 +0000
EFTA00030096


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c3: VOL00008
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=== Page 1 ===
From:
Subject: RE: Mark Epstein Emails
Date: Tue, 26 May 2020 14:31:03 +0000
Thanks for this. Sorry I was so out of the loop on this all weekend. I'm always happy to help out - just let me know if
there's anything I can do.
From: Donaleski, Rebekah (USANYS)
Sent: Tuesday, May 26, 2020 10:29 AM
To:
is
Subject: Mark Epstein Emails
Saved here: \\usa.doj.gov\cloud\nys\StAndrews\Shared\InReEpsteinDeath-2019R01059\Mark Epsteir
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00031510


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c3: VOL00008
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=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
July 2, 2020
The Honorable Katharine H. Parker
United States District Court
Southern District of New York
Re:
Unsealing of Indictment 20 Cr. 330
Dear Judge Parker:
The Government respectfully requests that Indictment 20 Cr. 330 be unsealed and that a
United States District Judge be assigned to the case. A proposed order to that effect is attached.
This case is designated as a Wheel C case.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
Assistant United States Attorneys
Tel.:
Enclosure
EFTA00030350

=== Page 2 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Unsealing Order
— V. -
20 Cr. 330
GHISLAINE MAXWELL,
Defendant.
Upon the application of the United States, by the Acting United States Attorney for the
Southern District of New York, Audrey Strauss, by Assistant United States Attorney
;
It is found that the Indictment in the above-captioned case is currently sealed and the United
States Attorney's Office has applied to have that Indictment unsealed, and it is therefore:
ORDERED that the Indictment in the above-captioned action be unsealed and remain
unsealed pending further order of the Court.
Dated:
New York, New York
July 2, 2020
Kathaw H Parker
HONORABLE KATHARINE H. PARKER
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK
EFTA00030351

=== Page 3 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
ORDER
20 Cr. 330 ( )
(18 U.S.C. $$ 2422, 2423 (a), 1623, 371, & 2.)
AUDREY STRAUSS
Acting United States Attorney.
EFTA00030352


c1: EFTA00031393
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c3: VOL00008
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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: https://www.foxnews.com/us/forensic-pathologist-jeffrey-epstein-homicide-suicide
Date: Wed, 30 Oct 2019 12:39:36 +0000
Thanks. That's what I've done with one inquiry I've had so far.
Sent from my iPhone
On Oct 30, 2019, at 8:29 AM,
wrote:
Obviously we can't officially comment but we are confident it's bunk - this guy is pretty controversial and
they should consider the source - so do what you can to tamp down any hysteria.
Sent from my iPhone
On Oct 30, 2019, at 8:26 AM,
wrote:
Baden emphatically told FOX News this morning that his findings are more consistent with
strangulations: "I've not seen in 50 years where that occurred in a suicidal hanging case," the 85-year-old
medical legend told Fox News.
We'll get a lot of inquiries about this today.
Sent from my iPhone
EFTA00031393


c1: EFTA00031846
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031846.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: FW: Application for Search Warrant
Date: Fri, 26 Jun 2020 01:49:32 +0000
Attachments:1)_Application_&_Affidavit_for_SW_for_all_JE_electronic_devicespdf
FYI, I corrected a typo the judge caught.
From:
Sent: Thursday, June 25, 2020 9:48 PM
To: Gorenstein NYSD Chambers
Cc:
is
)
Subject: RE: Application for Search Warrant
Thank you very much. Attached please find a revised affidavit correcting the error that Judge Gorenstein identified.
I will call the number provided at 9:10am tomorrow with the agent on the line.
Respectfully,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Gorenstein NYSD Chambers
Sent: Thursday, June 25, 2020 7:43 PM
To:
Cc:
is
)
Subject: Re: Application for Search Warrant
Judge Gorenstein has reviewed the warrant materials. Please call him at (917) 882-3627 with your agent on the
line at 9:10 a.m. If there is no answer, please leave a callback number by voicemail or text and the Judge will
respond to you shortly thereafter. If you need a different call-in time, please let us know. Additionally, Judge
Gorenstein notes the following: "While it does not affect probable cause, the warrant application in paragraph
4 and Attachment A refers to Epstein being arrested on July 6, "2020." The AUSA may wish to send a new
application that provides a correct date."
EFTA00031846

=== Page 2 ===
From:
Sent: Thursday, June 25, 2020 4:58 PM
To: Gorenstein NYSD Chambers
Cc:
is
Subject: Application for Search Warrant
Good afternoon,
Attached for Judge Gorenstein's review please find an application for a search warrant, as well as a proposed warrant.
The agent is available to swear out this warrant tomorrow morning whenever would be convenient for the Court. I can be
reached on my cellphone at 347-344-8771.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00031847


c1: EFTA00031434
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031434.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: U.S. V. Thomas, No. 19 Cr 830 - Discovery Production 7
Date: Wed, 14 Apr 2021 13:44:41 +0000
Attachments:2021.0414_Thomas_Discovery_Letter_-_Production_7-pdf;SDNY_00018025-
SDNY_00018025_(AEO).pdf
Counsel,
Please find attached a letter regarding the Government's production in this case. We are uploading a zip file containing
the discovery materials to USAfx. Additionally, please find attached one additional page of discovery, which has been
marked attorney's eyes only. Please contact us with any questions or if you have any difficulty accessing the production.
Regards,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031434


c1: EFTA00030274
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=== Page 1 ===
From:
To:
Subject: indictment
Date: Fri, 14 Jun 2019 21:24:10 +0000
Importance: Normal
Attachments: 2019-06-14_Epstein_Indictment.agm.docx
To make it easier for the review process, I accepted all of
edits, and then redlined (mostly for accuracy), with a
few comments. I want to think a bit about the level of detail that's added here, and the degree to which that's
problematic, but here's a starting point for revisions.
Assistant United States Attorney
Southern District of New York
EFTA00030274


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=== Page 1 ===
EXPERIENCE
United States v. Jeffrey Epstein: Supervised investigation and prosecution of
financier Jeffrey Epstein on sex trafficking charges.
EFTA00030970

=== Page 2 ===
EDUCATION
EFTA00030971


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=== Page 1 ===
From:
To:
Cc:
Subject:
Date: Mon, 01 Feb 2021 15:02:26 +0000
Embedded: FW: Next week - meet re:_Jeffrey_Epstein.msg; FW:
RE:
Here are the emails
sent us back in 2018 I believe.
EFTA00031084


c1: EFTA00030828
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c3: VOL00008
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=== Page 1 ===
DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
06/19/2019 17:52 EDT
Generated By:
Page 1 of 7
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
P
PP0232844
06/14/2019
*GA
N212JE
O
APIS
PASSENGER
LFPB
KTEB
00:00
06/12/2019
AF
11
0
APIS
NOT ON
CDG
JFK
00:00
BOARD
P
565848821
06/05/2019
DL
676
I
A512
APIS
12:16
P
565848821
06/05/2019
DL
676
I
APIS
REQUEST
JFK
STT
00:00
P
565848821
05/15/2019
DL
676
I
A512
APIS
12:27
P
565848821
04/14/2019
AA
207
I
A520
KIOSK 10
APIS
PASSENGER
MIA
MXP
15:10
GLOBAL ENTRY
KIOSK,
NORTHTERMD
P
565848821
04/08/2019
EK
206
O
APIS
ON BOARD
MXP
JFK
00:00
P
565848821
03/15/2019
*GA
N212JE
I
A523
APIS
PASSENGER
KPBI
TIST
17:32
P
565848821
03/14/2019
*GA
N212JE
0
APIS
PASSENGER
TIST
KPBI
00:00
P
565848821
02/19/2019
AA
63
I
A520
NTERMD KIOSK
APIS
PASSENGER
MIA
CDG
15:24
5 GLOBAL
ENTRY KIOSK,
MIA
P
565848821
02/09/2019
AF
99
0
APIS
ON BOARD
CDG
MIA
00:00
P
565848821
02/08/2019
*GA
N212JE
I
A523
APIS
PASSENGER
KPBI
TIST
16:46
P
565848821
02/08/2019
*GA
N212JE
I
APIS
PASSENGER
KPBI
TIST
00:00
02/06/2019
AF
99
0
APIS
NOT ON
CDG
MIA
00:00
BOARD
P
565848821
01/16/2019
*GA
N212JE
I
A523
APIS
PASSENGER
KPBI
TIST
17:12
P
565848821
12/23/2018
AT
202
I
A477
1 LANE 18
APIS
PASSENGER
JFK
CMN
00:31
K03 GLOBAL
ENTRY KIOSK,
TERM
12/13/2018
SU
101
0
APIS
NOT ON
svo
JFK
00:00
BOARD
P
565848821
11/28/2018
*GA
N212JE
I
A10D
APIS
PASSENGER
KTEB
TIST
15:27
P
565848821
11/28/2018
*GA
N212JE
0
APIS
PASSENGER
KTEB
TIST
00:00
For Official Use Only / Law Enforcement Sensitive
EFTA00030828


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=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
Date: Mon, 09 Nov 2020 15:27:24 +0000
Yes, that works, thanks.
From: Weinstein, Marc A.
Sent: Monday, November 9, 2020 10:24 AM
To:
;
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
Thanks. Would 4:30 work?
MarcA. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate,
distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail
transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain
viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If
verification is required please request a hard-copy version.
From:
Sent: Monday, November 9, 2020 10:23 AM
To: Weinstein, Marc A.
is
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
We are available for a call this afternoon - what works best for you?
Thanks,
From: Weinstein, Marc A.
Sent: Monday, November 9, 2020 9:50 AM
To:
)
is
Cc: Andrew Tomback
Subject: Epstein Estate update
and
:
Would you have time for a call this afternoon to give you an update on a new development?
Thanks,
Marc
MarcA.Weinstein I Partner
EFTA00029985

=== Page 2 ===
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.
EFTA00029986


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=== Page 1 ===
Subject: Re: Epstein Passport Photos
Date: Wed, 17 Jul 2019 19:32:49 +0000
Thanks
> On Jul 17, 2019, at 15:23
rote:
>
>
thanks very much for these. To confirm, we've received three emails, with nine photos total - let us
know if that's everything or if we should have received (or should be expecting) more? And thanks again.
>
> Subject: Epstein Passport Photos
>
> Please let me know if there are issues opening and I can resend. Due to size, had to send multiple emails.
V
> Thanks,
>
> FBI New York C20
> VCAC/Human Trafficking
V V V V V
EFTA00030612


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=== Page 1 ===
HYPERION AIR, INC.
PASSENGER MANIFEST
Registration Number: N909JE
Type: G-1159B
Pilots:
DATE: 9.2.2004 2004
FROM PBI
TO
TEB
Departure Time 909 AM PM
Arrival
AM
Trip
Time
11:10
PM
Number
1727
PASSENGERS
1. Jeffrey Epstein
FROM Identifier Defined
2."
City WEST PALM BEACH
3.
State or Country
FL
4.
TO Identifier Defined
5.
City TETERBORO
6.
State or Country
N.J.
7.
Nautical Miles
900
8.
Statute Miles
1035
9.
Gallons 1800
AIRFRAME
10.
Pounds
9234
96617
11.
Flight Time 2+16
23
12.
Altitude FL PL410 96640
13.
TAKE-OFF POWER
Night
.
COMMENTS
Flex Take-Off
T/L
/
Min Take-Off
-
IMC
-
Condition
Approach
RePositron to TEB POE to
HURRICANE FRANCES
EFTA00030273


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=== Page 1 ===
From:
)"
To: Arraignment NYSD
Subject: RE: Application for Search Warrant
Date: Fri, 26 Jun 2020 15:33:05 +0000
Inline-Images: image001.jpg
Thank you so much. Have a great weekend.
Take care,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Arraignment NYSD
Sent: Friday, June 26, 2020 10:44 AM
To:
Cc: Arraignment NYSD
Subject: FW: Application for Search Warrant
Good Morning
Your signed warrant is attached.
Have a great weekend
Vinny
UNITED STATES DISTRIC COURT
Vincent Babino
Arraignment Unit Clerk
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Phone:
DISTRICT
0
FAX:
From: Gabriel Gorenstein
Sent: Friday, June 26, 2020 9:35 AM
To: Arraignment NYSD
Subject: Fw: Application for Search Warrant
signed warrant
EFTA00031841

=== Page 2 ===
contact AUSA below
From:
Sent: Thursday, June 25, 2020 9:48 PM
To: Gorenstein NYSD Chambers
Cc:
is
Subject: RE: Application for Search Warrant
Thank you very much. Attached please find a revised affidavit correcting the error that Judge Gorenstein identified.
I will call the number provided at 9:10am tomorrow with the agent on the line.
Respectfully,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gorenstein NYSD Chambers
Sent: Thursday, June 25, 2020 7:43 PM
To:
Cc:
is
Subject: Re: Application for Search Warrant
Judge Gorenstein has reviewed the warrant materials. Please call him at
with your agent on the
line at 9:10 a.m. If there is no answer, please leave a callback number by voicemail or text and the Judge will
respond to you shortly thereafter. If you need a different call-in time, please let us know. Additionally, Judge
Gorenstein notes the following: "While it does not affect probable cause, the warrant application in paragraph
4 and Attachment A refers to Epstein being arrested on July 6, "2020." The AUSA may wish to send a new
application that provides a correct date."
From:
Sent: Thursday, June 25, 2020 4:58 PM
To: Gorenstein NYSD Chambers
Cc:
is
Subject: Application for Search Warrant
EFTA00031842

=== Page 3 ===
Good afternoon,
Attached for Judge Gorenstein's review please find an application for a search warrant, as well as a proposed warrant.
The agent is available to swear out this warrant tomorrow morning whenever would be convenient for the Court. I can be
reached on my cellphone at
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031843


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: https://www.foxnews.com/us/forensic-pathologist-jeffrey-epstein-homicide-suicide
Date: Wed, 30 Oct 2019 12:58:43 +0000
FWIW: from a reporter "Epstein's brother who hired him is telling him to go do this cause they feel like they're
not getting any answers. So there you go. All makes sense now."
Sent from my iPhone
On Oct 30, 2019, at 8:29 AM,
wrote:
Obviously we can't officially comment but we are confident it's bunk - this guy is pretty controversial and
they should consider the source - so do what you can to tamp down any hysteria.
Sent from my iPhone
On Oct 30, 2019, at 8:26 AM,
wrote:
Baden emphatically told FOX News this morning that his findings are more consistent with
strangulations: "I've not seen in 50 years where that occurred in a suicidal hanging case," the 85-year-old
medical legend told Fox News.
We'll get a lot of inquiries about this today.
Sent from my iPhone
EFTA00031394


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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Press remarks
Date: Fri, 26 Jun 2020 15:17:43 +0000
Attachments: Ghislaine_Maxwell_Press_Remarks.ebd.docx
Rough draft attached. I am assuming Audrey will be more conservative when it comes to anything beyond the Indictment,
so I tried to keep it kept it pretty tightly tethered to the language in the current draft.
EFTA00030505


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030977.pdf
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c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject:
Date: Fri, 22 May 2020 15:53:47 +0000
Attachments: 2020-05-19_perjury_and
supplement.rc.docx
We're probably going to send you a combined markup later today, but if you wanted to get started, here are my edits and
comments.
EFTA00030977


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=== Page 1 ===
From:
)"
To:
Subject: RE: Epstein case/NYPD Sex Offender Monitoring Unit
Date: Thu, 11 Jul 2019 01:20:04 +0000
Importance: Normal
Hugely appreciated - thank you.
From:
Sent: Wednesday, July 10, 2019 15:21
To:
Subject: Re: Epstein case/NYPD Sex Offender Monitoring Unit
I will call personally and explain it's importance to them. No problem
On Jul 10, 2019, at 3:18 PM,
)
wrote:
Lt.
Understood, and thanks very much. Just on the risk assessment, is there any way at all for them to pull that? We expect
we may get questions on it at the bail hearing on Monday, so totally understand it's with the vendor but if it's all
possible to pull that file so we can have a copy that would be great - just wanted to check.
thanks very much again,
From:
Sent: Wednesday, July 10, 2019 08:25
To:
Cc:
is
Subject: Re: Epstein case/NYPD Sex Offender Monitoring Unit
The discovery of the photographs will not have any effect on, nor will it alter, the status of his sex offender
registration. We have conferred with the NYS Division of Criminal Justice Services (DCJS) in Albany in order to
obtain his case file which would include the risk assessment. They are in the middle of a multi-year project to
digitally scan all of their docs and the Epstein file is with the vendor. We should have it within 10 days.
Lt.
New York City Police Department
Special Victims Division
Commanding Officer
Sex Offender Monitoring Unit
, N.Y, N.Y.
From:
)
Sent: Wednesday, July 10, 2019 12:30 AM
EFTA00030164

=== Page 2 ===
To:
Cc:
);
Subject: RE: Epstein case/NYPD Sex Offender Monitoring Unit
Lt.
Thanks very much for being in touch, and I'm in receipt of your email - should Mr. Epstein be granted bail and released, I
will certainly advise his attorneys that he or they must contact you immediately to arrange for the processes required in
New York State. I'm also copying my colleagues on the case, prosecutors
and
so they're
aware of the issue as well.
Separately, at the bail hearing yesterday the judge asked if there is any effect from the discovery of nude and partially-
nude photographs of women and girls who appear to be young, including possibly under 18 years of age, discovered
during a search on Saturday in his New York residence. Do you know if there is any impact of that with respect to his
New York registration and/or offender status? Or if there's another person I should check with about that? I'm happy to
give anyone a call.
Similarly, I believe that there may have been a 2011 state risk assessment in connection with Epstein-is it possible to
obtain a copy of that?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Tuesday, July 09, 2019 12:22
To:
Subject: Epstein case/NYPD Sex Offender Monitoring Unit
Mr.
Thank you very much for taking the time today to speak to me regarding the Epstein case. As I mentioned Mr.
Epstein is a registered Level 3 sex offender in the State Of New York and should he be released and establish
residence in NYC he is legally obligated to appear at my office ever 90 days. In addition, he is required to have
a new photo taken every 3 years (his current photo is 9 years old). If he is released his immediate appearance
at my office should be mandatory. Please feel free to reach out to me should you have any additional
questions or concerns in this matter.
Lt.
New York City Police Department
Special Victims Division
Commanding Officer
Sex Offender Monitoring Unit
, N.Y, N.Y.
EFTA00030165


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=== Page 1 ===
From
To:
)"
Cc: "Kate L. Doniger"
Subject: Estate of J. Epstein
Date: Tue, 04 Feb 2020 15:57:57 +0000
Inline-Images: image003.png; image004.png
Judge Grants USVI Intervener Status In Pending Courtroom Battle Over Jeffrey Epstein's Fortune
Judge Grants USVI Intervener Status In Pending
Courtroom Battle Over Jef...
ST. THOMAS - The Virgin Islands Department of Justice (V.I.D.O.J.)
is moving aggressively to secur...
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.
EFTA00031724


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=== Page 1 ===
From: "Weinstein, Marc A." <marc.weinstein@hugheshubbard.com>
To:
)"
)"
>, "Tomback, Andrew" <andrew.tomback@whitecase.com>
Subject: Epstein estate call
Date: Mon, 25 Nov 2019 14:30:59 +0000
Importance: Normal
Attachments: unnamed
Inline-Images: ATT91199_1.jpg
HHR OnlineMeetingCenter
Dial-In Information (for meetings with no presentations or video)
Dial-In Number: +1 (201) 630-0824
Conference ID: 169269771
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
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Full list of dial-in numbers
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Joining from a computer using the "Connect from computer or mobile device" link provides additional
capabilities, however you can simply call in from your telephone using the number provided above if your
meeting will not include video or a presentation. Click the "Help" link for additional information if you are a
guest joining a Skype for Business meeting from your computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
EFTA00029636


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
)"
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
Date: Mon, 09 Nov 2020 15:30:28 +0000
Thanks. I just sent a dial-in.
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Monday, November 9, 2020 10:27 AM
To: Weinstein, Marc A.
>;
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
CAUTION: This email was sent by someone outside of the Firm.
Yes, that works, thanks.
From: Weinstein, Marc A.
Sent: Monday, November 9, 2020 10:24 AM
To:
is
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
Thanks. Would 4:30 work?
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
EFTA00029982

=== Page 2 ===
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Monday, November 9, 2020 10:23 AM
To: Weinstein, Marc A.
is
Cc: Andrew Tomback
Subject: RE: Epstein Estate update
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
We are available for a call this afternoon - what works best for you?
Thanks,
From: Weinstein, Marc A.
Sent: Monday, November 9, 2020 9:50 AM
To:
is
Cc: Andrew Tomback
Subject: Epstein Estate update
and
:
Would you have time for a call this afternoon to give you an update on a new development?
Thanks,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
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.
EFTA00029983


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 30 Filed 07/27/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
AFFIDAVIT OF CERTIFICATION
V.
PURSUANT TO LOCAL
:
:
CRIMINAL RULE 16.1
GHISLAINE MAXWELL,
:
:
Defendant.
20 Cr. 330 (AJN)
:
:
X
I, Christian R. Everdell, an attorney duly admitted to practice in New York State and
before this Court, declare the following is true and correct under penalty of perjury pursuant to
28 U.S.C. $ 1746:
1.
I am a partner at Cohen & Gresser LLP, counsel for defendant Ghislaine Maxwell
in the above-captioned case.
2.
I certify pursuant to Local Criminal Rule 16.1 that defense counsel has conferred
in good faith with Assistant U.S. Attorneys
, and
regarding the government's proposed protective order pursuant
to Federal Rule of Criminal Procedure 16.
3.
While the parties have been able to agree on most of the provisions of the
protective order, we have been unable to resolve two narrow areas of dispute.
a. First, the defense believes that potential government witnesses and their
counsel should be subject to the same restrictions as the defense concerning
appropriate use of the discovery materials-namely, if these individuals are
given access to discovery materials during trial preparation, they may not use
EFTA00029877

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 30 Filed 07/27/20 Page 2 of 2
those materials for any purpose other than preparing for trial in the criminal
case, and may not post those materials on the Internet.
b. Second, the defense believes it should not be restricted from publicly
disclosing or disseminating the identity of any alleged victims or potential
witnesses referenced in the discovery materials who have already identified
themselves by speaking on the public record.
I hereby certify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements are willfully false, I am subject to punishment.
Dated: July 27, 2020
/s/ Christian R. Everdell
New York, New York
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, New York 10022
Phone: 212-957-7600
2
EFTA00029878


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=== Page 1 ===
From:
To:
Subject: Memo
Date: Wed, 14 Aug 2019 16:56:30 +0000
Attachments: 2019.08.14_JE_status_memo_for_Geoff.docx
Sorry, the guy I'm interviewing showed up early. This is still rough (particularly the
section), but wanted to send to
you before I'm out of pocket for the next chunk of time.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York. NY 10007
EFTA00029712


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: Re: laptop for MDC
Date: Wed, 28 Oct 2020 18:52:05 +0000
I can raise with her, thanks.
On Oct 28, 2020, at 2:48 PM,
)
wrote:
are you able to discuss this with
or would you like me to reach out to her? Thanks.
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:44 PM
To:
Subject: Re: laptop for MDC
It sure we will research one tonight and place the order tomorrow. It depends on availability and delivery. Do we have a
copy of the data that goes with the drive?
Also with the ever changing policies in BOP, can you confirm that they will allow her to have a laptop. Not sure the rules
at MDC.
Sent from my iPhone
On Oct 28, 2020, at 2:22 PM,
wrote:
Perfect, thanks so much. How long would you estimate that will take?
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:20 PM
To:
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
We will spec out a laptop to purchase for this case.
From:
Sent: Wednesday, October 28, 2020 2:09 PM
To:
(USANYS)
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
Thanks so much.
EFTA00030579

=== Page 2 ===
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:06 PM
To:
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
Let me discuss with
the best options. get back to you shortly.
From:
)
Sent: Wednesday, October 28, 2020 1:58 PM
To:
(USANYS)
Cc:
)
is
(USANYS)
Subject: laptop for MDC
Hi
I hope you're doing well. Because of some discovery accessibility issues we're having in the Ghislaine Maxwell case, we
would like to provide a clean laptop to Maxwell in MDC for discovery review purposes. The laptop need only permit
review of standard files - word, pdf, .tif, .xls, etc. All other capabilities and programs can be disabled. I understand we
did something similar in the Avenatti case, and we'd like to do the same here. Would that be possible? It would be a
huge help to us if you could possibly prep and provide us with a laptop for this purpose.
Thanks so much-
EFTA00030580


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=== Page 1 ===
Page 1 of 3
---START MESSAGE Subject: eFOIA Request Received Sent: 2018-12-06T12:21:29.820058+00:00 Status: pending Message:
Individual Information
Prefix
First Name
Live
Middle Name
Last Name
Attempt
Suffix
Email
Phone
Location
United States
Domestic Address
Address Line 1
NA
Address Line 2
City
NA
State
California
Postal
NA
Agreement to Pay
How you will pay
am requesting a fee waiver for my request and have reviewed the FOIA reference guide If my fee
waiver is denied, I am willing to pay additional fees and will enter that maximum amount in the box below
Allow up to $
1,000
Proof Of Affiliation for Fee Waiver
Waiver Explanation
This request is NOT for any commercial use. This request is being made
specifically because or the compelling public interest in the rBI's
operations as they relate to convicted and prolific SEX offenders like
Jeffrey Epstein. Furthermore, open source reporting shows that Epstein had
close ties with former president Bill Clinton, current president Donald
Trump, Prince Andrew, and other politicians and heads-of-state. For that
additional reason, the public interest here outweighs any on-going right to
privacy that may be in play.
"Documents shall be furnished without any charge or at reduced rate If
disclosure of the information is in the public interest because it is likely
to contribute significantly to public understanding of the operations OF
activities of the government and is not primarily in the commercial interest
of the requester."
All 4 of the factors are net in this case. 1) The request is clearly related
to the operations of the federal government in general and the FBI in
particular. 2) The request 1# likely to contribute to the public's
understanding of the FBI's handling of Epstein. 3) The request is likely to
contribute to the public's understanding IT intend to publish all records
received), and 4) Considering Epstein's reported ties to former and current
presidents and royals, any information you can provide would absolutely be
significant.
Documentation Files
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/b83d/EMailCorrespondence.html
12/19/2018
EFTA00030118

=== Page 2 ===
Page 2 of 3
Non-Individual FOIA Request
Request Information
I am requesting records related to Jeffrey Epstein (DoB: 01/20/1953), and
the investigation that vas conducted between roughly 2006 and 2010.
Specifically, I - requesting the following:
1) Copies of any and all unredacted investigative reports that have not
already been published https://voulb.fbi.gov/jcffrey-spstsin.
2) Any and all video and photos taken by investigators as part of the
aforementioned investigation.
3) Any and all videos and photos that were collected as evidence from
Epstein's property houses, planes, etc.).
4) Names of any and all co-conspirators that were identified during the
course of the aforementioned investigation.
5) Confirmation as to whether any additional investigations have been
undertaken in to Epstein or any of the co-conspirators that were identified
subsequent to the aforementioned investigation.
6) Copies of any and all directives, policies, instructions, or agreements
relating to the FBI's investigations into Epstein and his co-conspirators,
especially any that may, in any way, limit, hinder, or prevent the FBI from
investigating or prosecuting Epstein and/or his co-conspirators.
7) Copies of any emails sent OF received by Robert Mueller (then head of the
FBI) that include the word "Epstein" or that otherwise relate to the
aforementioned investigation.
Expedite
Expedite Reason
I = requesting this request be expedited on the following basis:
1) The request is made by a person primarily engaged in disseminating
information to the public and the information is urgently needed to inform
the public concerning some actual or alleged federal government activity
: intend to publish (non-commercially) any and all responsive records that
you provide, specifically for the purpose of disseminating said information
** the public The information is urganaly - inform the public about
a matter that is currently making headlines (e.d.,
2) The subject of the request is of widespread and exceptional media
interest and the information sought involves possible questions about the
government's integrity which affect public confidence.
This subject is unquestionably of widespread and exceptional media interest
(sample of recent news stories below), and the information requested speaks
directly to the government's integrity in investigating and prosecuting
prolific child #** predators, which absolutely affects public confidence.
tps://www.washingtonexaminer.com/policy/economy/democrats-seek-justice-investigation-into-labor-secretary-a
https://www.thedailybeast.com/lamakers-demand-probe-of-laborrsecretaryracostiroverrsexrabuser-jeffrey-spstai
https://www.miamiherald.com/latest-mevs/article222597266.html
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request may be directed to foipaquestions@fbi.gov. If you
have received a FOIPA request number, please include this in all correspondence concerning your request. Please note eFOIPA requests are processed in the order that they
are received. If you have not received a FOIPA request number, your request is in the process of being opened at which time it will be assigned a FOIPA request number
and correspondence will be forthcoming.
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI&ETMs electronic FOIA Library (The Vault) on the FBIa€ᵀMs
public website, http://vault.fbi.gov by clicking on the &€"Check Status of Your FOI/PA Request toola€ᵀ link. Status updates are performed on a weekly basis. If you
receive a comment that your FOIPA request number was not located in the database, please check back at a later date.
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/b83d/EMailCorrespondence.html
12/19/2018
EFTA00030119

=== Page 3 ===
Page 3 of 3
END MESSAGE
----
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/b83d/EMailCorrespondence.html
12/19/2018
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=== Page 1 ===
From:
)"
To:
)"
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Date: Mon, 13 Jul 2020 20:41:19 +0000
Ugh, first I miss her call and then fail to hit reply all.
Everything okay?
Sent from my iPhone
On Jul 13, 2020, at 16:40,
)
wrote:
On the phone with her now.
From:
Sent: Monday, July 13, 2020 4:39 PM
To:
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
I think I may have just missed a call from you - I'm available now on my cell if you want to try me again, sorry
about that!
Sent from my iPhone
On Jul 13, 2020, at 13:34,
wrote:
Hi
Thanks very much.
From:
Sent: Monday, July 13, 2020 1:31 PM
To:
is
)
Cc:
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
Working on getting you that confirmation/what BOP would be comfortable putting in a public filing. Will aim to get that
to you before the arraignment tomorrow.
Best,
>>>
)"
> 7/12/2020 4:17 PM >>>
Thanks,
On a separate subject, is it correct that, for security reasons, the defendant is being housed in her own
cell (without a cellmate), and that her exercise time is separate from other inmates? That is our current understanding,
EFTA00030386

=== Page 2 ===
but we wanted to confirm, and also to make sure the BOP would not have an issue if we referenced this in public
filings.
Thanks,
From:
Sent: Sunday, July 12, 2020 4:13 PM
To:
Cc:
is
)
is
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
Thanks for the update, and totally understand it's over a weekend, and we did not know that defense counsel had also
been having additional afternoon calls, so that's helpful to know. Also helpful to know that you have not received
other calls or emails from counsel. We'll let her counsel know that they will have calls tomorrow and Tuesday at 10:00
a.m., and thanks very much again for your help.
From:
Sent: Sunday, July 12, 2020 15:28
To:
Cc:
is
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Apologies all, I just saw these emails. We are not providing weekend calls generally at this time, and counsel has been
having 2 hour legal calls every afternoon in addition to the standing call set up in the morning. This is far more than
almost every other inmate receives prior to an arraignment. Most other arraignments have been set up with one or two
days notice, with only one call to counsel and one call to pretrial services.
I have received no calls or emails from counsel, so I'm not sure where they have made these emergency requests.
They will have another call with her tomorrow, and I can let staff know they will request the call on Tuesday as well.
>>>
)"
> 7/12/2020 12:42 PM >>>
Following up, we heard from defense counsel that they didn't receive a call this morning either and that they filed an
emergency request but haven't heard back. Please let us know the status as soon as possible? They also wanted to
confirm that they will have calls at 10:00 tomorrow and Tuesday. Again, we realize this is unusual but I'm not aware of
any other defendants who are in this circumstance of having a bail hearing pending in just two days. Also copying
in case he's aware of someone else we should contact.
thank you,
On Jul 12, 2020, at 09:24,
<
>
wrote:
EFTA00030387

=== Page 3 ===
Following up on this - we understand that as of Tuesday defense counsel will go through the normal process, but
since the client's bail hearing is Tuesday they did anticipate being able to speak with her this weekend and tomorrow
in advance. Thanks again and sorry for the bother.
On Jul 11, 2020, at 17:16,
)
>
wrote:
We just were contacted by defense counsel, who said they didn't have a call with their client this morning - I think
they expected that the morning calls up until her arraignment on Tuesday would include the weekend. Is it
possible to reinstitute the call for tomorrow at 10:00, as well as on Monday? Thanks very much, and sorry for the
late notice - we just heard from them a moment ago.
thanks,
From:
Sent: Friday, July 10, 2020 10:34
To:
Cc:
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Great - thank you again! (I told defense counsel that I would ask, but also just to give it a few minutes
.)
Sent from my iPhone
On Jul 10, 2020, at 10:30,
wrote:
I've been informed she is on the phone
)"
7/10/2020 10:26 AM
Defense counsel for Maxwell communicated to us a few minutes ago that they haven't gotten a call yet this
morning. Do you know if that has gone through in the past five or ten minutes? They are looking to speak with
her before her interview with pretrial this afternoon.
I'm reachable at
if it's useful to chat in real time.
thanks,
On Jul 7, 2020, at 19:50,
wrote:
,
You're welcome. We will do our best to provide a call at 10:00 AM every day this week to Mr. Everdell
at the number he has previously provided. We will also provide a call on Monday 7/13/20.
The EDNY and SDNY created a joint protocol whereby counsel may request legal calls to be placed in
the afternoon at the MDC. Requests should be sent to
Truly urgent requests can be sent to me, but unless there is a last minute, imminent court deadline,
counsel really should send the requests to the federal defenders, as outlined in the protocol. We want to
ensure inmates get equitable access. If they anticipate needing several calls in a week, they should
make requests in advance and note whether and when calls would be preferred. Generally, calls are for
30 minutes in duration. If a longer call is desired, that should be explained as well.
If you need anything else, please let me know.
EFTA00030388

=== Page 4 ===
Thank you,
)"
7/7/2020 5:00 PM
Thank you so much,
A 10am standing legal call every day before the arraignment on Tuesday 7/14 would be perfect if that's
something you would be able to accommodate. Defense counsel will be available at that time, and they are
very grateful for the time.
We have also conveyed to defense counsel that they will need to follow the same protocols as other inmates'
counsel following the arraignment. Thank you for letting us know about the lack of requests from defense
counsel thus far. There appears to be some confusion on their end about how to submit requests to schedule
legal calls. Would you be able to please share with us the procedure that they should follow, so that we can
make sure they understand what steps to take going forward?
Thank you again for all of your help-we really appreciate it.
Best,
From:
Sent: Tuesday, July 7, 2020 4:23 PM
To:
Cc:
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
You're welcome.
Would 10 am work as a standing legal call through the end of this week (and Monday, if you think that's a good
idea), in advance of the arraignment on Tuesday? However, after this, defense counsel should be required to
follow the same protocols as all other inmates' counsel with respect to requesting legal calls.
I also just want to make clear that defense counsel sent no requests yesterday that I am aware of, and we were
able to facilitate a call yesterday evening following a request from your office, and today, I received one request,
about mid-day, that we were again able to accommodate. So, I do not think it is fair at all to categorize this as
defense counsel having difficulty scheduling legal calls.
Thank you,
>>>
)"
7/7/2020 2:37 PM >>>
Thanks,
This is about the legal call today. In addition, because defense counsel his having difficulty
scheduling legal calls, it would be helpful if MDC could schedule standing calls for the rest of this week to
address this issue. Thanks very much.
From:
Sent: Tuesday, July 7, 2020 2:36 PM
To:
Cc:
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Hi
I just saw this now. Is this about the legal call issue or something separate? If it's about the legal call, I am
working on it.
Thanks,
>>>
)"
7/7/2020 1:27 PM >>>
Hi
Thanks for your help with this. Are you available now for a call? We are having a time sensitive issue with this.
Thanks,
EFTA00030389

=== Page 5 ===
Sent from my iPhone
On Jul 6, 2020, at 7:59 PM,
> wrote:
Hi
For future reference, there is a protocol in place for defense counsel to reques legal calls. If counsel is unaware
of it, I can provide the details.
However, I understand that she just came into custody today and there is a more urgent deadline. If you can
please provide the name and phone number of counsel, I will do my best.
Thanks,
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
>
Date: 7/6/20 7:48 PM (GMT-05:00)
To:
>
Cc:
>,
>
Subject: Ghislaine Maxwell (USMS No. 02879-509)
>>>
)" 07/06/2020 19:48 >>>
Hi
Hope you're doing well. This evening, Judge Nathan directed the parties in the US V. Ghislaine Maxwell case to
file a letter by 9pm today. Defense counsel need to speak with Ms. Maxwell this evening about the letter, but
they have not been able to reach her. Would it be possible to allow Ms. Maxwell to make a legal call to her
lawyers this evening, please?
Thank you very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00030390


c1: EFTA00031176
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031176.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Subject: RE: Epstein search warrant documents
Date: Fri, 19 Jun 2020 17:44:28 +0000
Will do.
From:
(USANYS)
Sent: Friday, June 19, 2020 13:44
To:
y.
(USANYS)
Subject: RE: Epstein search warrant documents
Okay, please keep us posted on this regularly. In particular, let us know if you end up getting the phone/ipad from
this afternoon as promised.
From:
Sent: Friday, June 19, 2020 1:43 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein search warrant documents
I just had positive conversations with
and
(and
-
had understood that FBI was getting their own
hard drive to transfer the data, which obviously makes sense.
response to
email was to just have
order a 12 TB drive, which she expects will get to
next week. I also think that's a better option than the 2 TB
drive that
says we have available on short notice, given that we expect the data to be somewhere around 20-40 TB
(the capacity of the devices we seized is around 40-50 TB).
I take it from
email that he's otherwise ready to give us the data, although that certainly would be a new
development, but we're obviously hopeful that's the case. The key question then will be whether what we get from him
this time is actually usable. If it's not, I think at that point it will make sense to just have BRG do it - they can physically
take the devices themselves and do it. We had asked about that possibility from the beginning and CART was resistant,
but given the past nine months I think we should do it if necessary. But, hopefully the intervention of higher-ups solves
the problem and we can get the data in the next couple weeks, which would be great.
From:
(USANYS)
Sent: Friday, June 19, 2020 13:36
To:
Cc:
(USANYS)
Subject: FW: Epstein search warrant documents
Are we just talking about getting these across the street? He should not ship them. Maddie can bring.
From:
(USANYS) [Contractor]
Sent: Friday, June 19, 2020 1:35 PM
To:
(NY) (FBI)
is
Cc:
(USANYS)
is
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
EFTA00031176

=== Page 2 ===
is
(USANYS)
Subject: RE: Epstein search warrant documents
Hello
I can have the drives shipped to you or if you want you can come and pick up the drives from Saint Andrews. Someone
would be available for you to meet up with between 9:30 am - 12:30 pm Monday - Friday. Please let me know which you
prefer.
Thank you.
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 1:14 PM
To:
(USANYS) [Contractor]
>;
)
Cc:
(USANYS)
i
(NY) (FBI)
>;
i
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
-
is
)
is
(NY) (FBI)
in
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
EFTA00031177

=== Page 3 ===
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
in
Cc:
(NY) (FBI)
i
in
)
is
,
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
V.
-
Cc:
(NY) (FBI)
i
)
in
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
EFTA00031178

=== Page 4 ===
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
EFTA00031179

=== Page 5 ===
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
>;
(USANYS) [Contractor]
Cc:
is
)
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00031180

=== Page 6 ===
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
EFTA00031181

=== Page 7 ===
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
>;
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
EFTA00031182

=== Page 8 ===
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
EFTA00031183

=== Page 9 ===
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
in
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
V.
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
EFTA00031184

=== Page 10 ===
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
V.
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
i
(NY) (FBI)
is
)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
is
i
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
EFTA00031185

=== Page 11 ===
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
i
is
(NY)
(FBI)
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.
EFTA00031186

=== Page 12 ===
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
V.
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
V.
V.
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
EFTA00031187

=== Page 13 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
in
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
)
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
EFTA00031188

=== Page 14 ===
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at -
which
,
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
in
(NY) (FBI)
Cc:
(USANYS) [Contractor]
in
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
EFTA00031189

=== Page 15 ===
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
EFTA00031190


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c3: VOL00008
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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
)
27 electronic devices seized on
August 12, 2019 from Little Saint James in the
)
Virgin Islands
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
Judge's signature
City and state:
New York, NY
Hon. James L. Cott, United States Magistrate Judge
Printed name and title
EFTA00030736

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00030737

=== Page 3 ===
Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
The Subject Devices were all recovered from a search of a private island in the U.S. Virgin
Islands, known as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019. The Virgin Islands Residence consists of multiple
structures, including a main residence as well as several other smaller structures on the island,
including a pool house, sheds, a beach house, an office, and multiple cabanas. The Subject Devices
are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a
desk in the main residence on the island ("Subject Device-1");
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT,
which was recovered from a desk in the main residence on the island ("Subject
Device-2");
c. A silver MacBook Pro bearing serial number c02qm0gugwdp, which was
recovered from a desk in the main residence on the island ("Subject Device-3");
d. A silver iPad model A1567 bearing serial number dmpql25ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-4");
e. A silver iPad model A1567 bearing serial number dmpqL1rmg5y, which was
recovered from a desk in the main residence ("Subject Device-5");
f. A silver Mac desktop computer bearing serial number c02nm1m0fy14, which was
recovered from a desk in the pool house on the island ("Subject Device-6");
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-7");
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a
shed on the island ("Subject Device-8");
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk
in a shed on the island ("Subject Device-9");
j. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-10");
2017.08.02
EFTA00030738

=== Page 4 ===
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana
on the island ("Subject Device-11");
1. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered
from a desk in the beach house on the island ("Subject Device-12");
m. A silver Mac desktop computer model A1311 bearing serial number
W804736DDAS, which was recovered from a desk in the beach house on the island
("Subject Device-13");
n. A Unfi video bearing mac ID 1829f b4fbe426ea90, which was recovered from a
server rack inside a shed on the island ("Subject Device-14");
O. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was
recovered from a server rack inside a shed in on the island ("Subject Device-15");
p. An HP server with four 500 GB drives, bearing serial number MXQ3220187, which
was recovered from a shed on the island ("Subject Device-16");
q. A Panasonic KX TDE100 computer bearing serial number KX-TDa0104
9LCCD005398, which was found on a server rack in a shed on the island ("Subject
Device-17");
Γ. A 6 bay with 146 GB drives bearing serial number MXQ824A1R, which was found
on a server rack in a shed on the island ("Subject Device-18");
S. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-19");
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which
was recovered from the maintenance office on the island ("Subject Device-20");
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was
recovered from the maintenance office on the island ("Subject Device-21");
V. A Mac desktop computer model A1312, bearing serial number w89524czspj, which
was recovered from the maintenance office on the island ("Subject Device-22");
W. A Lenovo tower machine type 90J0, bearing serial number mj07yg6u, which was
recovered the maintenance office on the island ("Subject Device-23");
X. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered
the maintenance office on the island ("Subject Device-24");
y. An HP Tower bearing serial number CNV74213M3 570-P056, which was
recovered the maintenance office on the island ("Subject Device-25");
2
2017.08.02
EFTA00030739

=== Page 5 ===
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgm9, which was found on a server rack in a shed on the
island ("Subject Device-26"); and
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in
a cabana on the island ("Subject Device-27").
II. Review of ESI on the Subject Devices
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Device for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
1.
Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices
2.
Evidence concerning the identity or location of, and communications with, co-
conspirators of Jeffrey Epstein, including
3.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
4.
Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
5.
Any photographs of victims or potential victims of the Subject Offenses.
6.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
7.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs.
8.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. $ 2256(8).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
3
2017.08.02
EFTA00030740


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c0:
=== Page 1 ===
From:
)"
To: "Moyne, Parvin"
Cc: "DiPiero, Joseph"
Moyer, Thomas"
)"
Subject: RE: Epstein accounts
Date: Mon, 18 Nov 2019 22:13:29 +0000
Parvin,
Thanks very much for sending - we've received the documents and we appreciate you bringing them to our attention.
thanks again,
From: Moyne, Parvin
Sent: Wednesday, November 13, 2019 21:20
To:
is
-
i
Cc: DiPiero, Joseph
Moyer, Thomas
Subject: Epstein accounts
As you know, we're in the process of reviewing the Bank's electronic communications related to its relationship with
Jeffrey Epstein. In the course of our ongoing review, we've located a chart which appears to identify Epstein's accounts at
J.P. Morgan prior to his transition to Deutsche Bank. The chart was attached to a September 12, 2013 email from Epstein's
accountant, Harry Beller, to Paul Morris's assistant, Amanda Kirby. The subject line of the email reads: "Let's discuss."
There is no text in the body of the email, but we know that Epstein was transferring assets from J.P. Morgan to Deutsche
Bank around this time.
Notably, the chart identifies several accounts that were previously unknown to us, including a brokerage account
belonging to the Butterfly Trust. The chart also identifies the managers of Epstein's J.P. Morgan brokerage and asset
trading accounts. While we had previously flagged Epstein's relationship to Paul Barrett, we were previously unaware of
Epstein's apparent relationship to Ted Serure or Laurie Cameron. As reflected in the chart, Ted Serure managed the
Butterfly Trust account, and, according to Barron's, he still works at J.P. Morgan Securities.
The referenced chart and email are attached. We will include a bates-stamped version of both documents in our next
production, which we are in the process of finalizing. That production will also include a significant number of emails
related to Darren Indyke's cash withdrawal activities. As always, we're happy to discuss if you have any questions or
would like us to follow up further.
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
New York, NY 10036-6745
USA
Direct:
Internal:
Fax:
akingump.com
Bio
EFTA00029805

=== Page 2 ===
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00029806


