# docs_fts_content

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=== Page 1 ===
From:
To:
Cc:
Subject: Re: epstein
Date: Wed, 10 Jul 2019 10:05:20 +0000
Importance: Normal
First I'm hearing about it assuming it's even true -
and
may know more.
Sent from my iPhone
On Jul 9, 2019, at 8:47 PM,
wrote:
FYI
From: Goldstein, Matthew
Sent: Tuesday, July 09, 2019 2:44 PM
To:
Subject: epstein
hi all
so we have been told that Deutsche Bank controls several billion in assets belonging to Financial Trust
Company on behalf of Epstein's customers. We are told that up until his arrest Epstein was trading currencies
through Deutsche for his client. We are told that Deutsche is considering going into bankruptcy court to take
control of these assets and is coordinating its efforts with your office. can you give me any guidance on this for
our story
matt
Matthew Goldstein
The New York Times
(w)
(c)
EFTA00018401


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c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019537.pdf
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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 17:27:35 +0000
Inline-Images: image001.png
Thanks very much!
From:
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
Hearty congratulations on this important step guys. Well done.
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 TOFFICE SESTICE
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,
EFTA00019537

=== 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.
EFTA00019538

=== 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.
EFTA00019539


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=== Page 1 ===
From:
To:
Ce:
(NY) (FBI)"
Subject: RE: Epstein investigation
Date: Wed, 28 Oct 2020 18:03:00 +0000
Good afternoon AUSA
The FOIA media team advised they downloaded media from file number 31E-MM-108062, including audio and video. However, there seem to be some technical issues,
as they are unable to listen to 48 audios located in the 1A Vol 3. Per our Document Conversion Unit, this is a "codec problem," meaning there was probably some sort of
user error from The AUSA's office when they exported the media to the disc. This issue cannot be resolved on our end. It would have to be addressed with whomever
sent us the media. With this one exemption, the rest of the media we downloaded to OPWAN is viewable. Please see below a list with a brief description of the items.
I'm not sure if this is all the media contained in the file though. Hope this helps. Please let me know if you have questions or need further assistance.
File
Type of Media
Length (hr, min, sec)
Description
31E-MM-108062-1A Vol. 3
48 Grand Jury Testimony audio files dated 7/19/2006 (media
(located in GJ-1A Sec. 03, FDPS pg. 250
Audio
3:08:54
received from the PB State Attorney's Office).
on T-drive)
31E-MM-108062-1A43
(located in 1A Sec. 05, FDPS Pg. 194 on
Audio
1:13:05
4/24/2007 interview of Ms.
by FBI SAs
and AUSA
T-drive)
(media received from SA
ICE).
31E-MM-108062-1A91
(located in 1A Sec. 11, FDPS pg. 83 on
Video
3:26:21
2/17/2010 deposition of Jeffrey Epstein
VS. Jeffrey
T-drive)
Epstein). Media received from attorney
Thanks,
Unit Chief
Litigation Support Unit/RIDS
Confidentiality Statement: This message is transmitted to you by the Litigation Support Unit of the FBI's Information Management Division. This message,
along with any attachments, may be confidential, law enforcement sensitive, and legally privileged. If you are not the intended recipient of this message,
please destroy it without further retention or dissemination (unless otherwise required by law). Please notify the sender of the error by separate e-mail or by
calling (540) 868-4843.
From:
Sent: Monday, October 26, 2020 5:46 PM
To:
Cc:
>;
(NY) (FBI)
(NYPD)
P;
(USANYS)
Subject: [EXTERNAL EMAIL] Re: Epstein investigation
Hi
Thanks very much for looking into this, we appreciate it.
Best,
Sent from my iPhone
On Oct 26, 2020, at 3:57 PM,
wrote:
Good afternoon AUSA
My apologies for the delay. I'm looking into this matter. Waiting for a response from the FOIA team that process media. I should have a response shortly.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
EFTA00018253

=== Page 2 ===
Confidentiality Statement: This message is transmitted to you by the Litigation Support Unit of the FBI's Information Management Division. This message,
along with any attachments, may be confidential, law enforcement sensitive, and legally privileged. If you are not the intended recipient of this message,
please destroy it without further retention or dissemination (unless otherwise required by law). Please notify the sender of the error by separate e-mail or by
calling (540) 868-4843.
From:
Sent: Monday, October 26, 2020 3:41 PM
To:
Cc:
is
(NY) (FBI)
is
(NYPD)
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein investigation
Hi
Just following up on this, thanks. Any information you could provide would be very helpful.
Thanks,
From:
Sent: Monday, October 19, 2020 6:34 PM
To:
Cc:
is
(NY) (FBI)
(USANYS)
Subject: RE: Epstein investigation
Hi
Hope you're doing well. As our team is reviewing these materials in connection with discovery, we wanted to follow up with you about this project. In particular, we
were hoping you could tell us how your office approached CDs that were in the boxes of materials from Florida. We noticed in the scans we received some documents
that looked like the attached file - which looks like a photocopy of the CD. Were those materials downloaded by your office? If not, no worries at all, we have them from
the primary file, but we wanted to check with you to make sure we had the complete set of materials you sent.
Thanks very much,
From:
Sent: Wednesday, February 13, 2019 9:53 AM
To:
Cc:
>;
(USANYS)
(NY) (FBI)
>;
Subject: RE: Epstein investigation
Hi
Wanted to quickly check in to follow up on our conversations last week and earlier this week - I think you were able to transmit the scanned records to
but I'm
not sure whether that was just the 16,000 pages you mentioned when we last spoke, or if you were able to get all 29,000 to her? And we're also hoping to confirm for
sure that all the materials you received were definitely scanned in, and to get an index or catalog of those materials (including what media was included).
Another person on our team,
who's copied, is jumping in to coordinate on this, so if it's easier to chat via phone her number is
and please
let us know if anything would be helpful on our end.
thanks again!
From:
Sent: Wednesday, January 30, 2019 17:19
To:
Cc:
is
(USANYS)
(NY) (FBI)
Subject: RE: Epstein investigation
EFTA00018254

=== Page 3 ===
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact info - I'm reachable at this email address or by
phone at
(office) or
(cell). Please don't hesitate to reach out anytime day or night if we can provide any useful info, or if you have any
questions at all, and we appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for Friday or early next week to
check in on the questions we had, and thanks very much for your help.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00018255


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
(USANYS)"
(USANYS)"
Subject: RE: Jeffrey Epstein/FOIA matters
Date: Fri, 12 Mar 2021 16:51:49 +0000
Hi all,
The only other SDNY case I am aware of (although I may not have heard of others) is/was being handled
copied here.
I do not know the status of that case, which I believe was against the FBI.
Otherwise, I thought
was keeping a list of Epstein-related FOIA requests, but I don't think they were all in
litigation.
Thanks,
From:
Sent: Friday, March 12, 2021 11:23 AM
To:
(USANYS)
Cc:
(USANYS)
(USANYS)
Subject: RE: Jeffrey Epstein/FOIA matters
Thanks,
Much appreciated.
From:
(USANYS)
Sent: Friday, March 12, 2021 11:18 AM
To:
Cc:
is
(USANYS)
;
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
I am copying
who is handling the main matter before Judge Engelmayer and who likely would
know if there are related FOIAs. I will also ask our civil clerk.
Sent from my iPhone
On Mar 12, 2021, at 10:59 AM,
wrote:
Hi
In connection with a criminal discovery matter,
and
and I are trying to find a list of all Jeffrey Epstein-
related FOIA lawsuits that the Civil Division has handled (either pending or historical). Our chiefs suggested that you
might be able to help us generate that list - if you have any guidance or information on how we could track this down,
EFTA00018986

=== Page 2 ===
we'd really appreciate your help. Or if there's someone else we should reach out to in the Civil Division instead, please
let us know.
Thanks so much-
Assistant United States Attorney
Southern District of New York
EFTA00018987


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=== Page 1 ===
From:
To:
)"
)"
)"
Subject: FW: Ghislaine Maxwell Siblings
Date: Wed, 01 Jul 2020 19:27:29 +0000
Good afternoon,
Below is information regarding Maxwell's siblings.
From:
Sent: Wednesday, July 01, 2020 2:55 PM
To: Young, Amanda N. (NY) (FBI) ;
Subject: Ghislaine Maxwell Siblings
1. Christine Maxwell
2. Isabel Maxwell
3. Karine Maxwell
DOB: 1947
Deceased
4. Ann (Anne) Maxwell (Anne Holve)
Married Lawrence Holve
No identified residence in US
i.
5. "Kevin Maxwell
No identified residence in US
i.
6. Michael Maxwell
DOB: 1946
Deceased
7. lan Maxwell
DOB:
No identified residence in US
i.
8. Philip Maxwell
DOB:
No travel history
No identified residence in US
Let me know if you need anything else!
EFTA00019413


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=== Page 1 ===
From:
Cc:
op.gov>
Subject: Epstein
Date: Tue, 13 Aug 2019 11:53:30 +0000
Good morning all,
Do you have records from his prior incarceration? Do you have a contact for his prior facility or the USAO in Florida? I have
been asked to track down certain documentation in reference thereto in relation to the various investigations into the
incident this past weekend.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
EFTA00019861


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=== Page 1 ===
SUMMARY OF GHISLAINE MAXWELL'S RELATED ACCOUNTS AS OF 6/30/2020 - DRAFT
6/30/2020
ACCOUNT HOLDERS'S
ACCOUNT
BALANCE (IN
FINANCIAL INSTUTITION
ACCOUNT NAME
STATEMENT ADDRESS
NUMBER
USD) (A)
COMMENT
SCOTT BORGERSON OR
MANCHESTER MA 01944-
USAA FEDERAL SAVINGS BANK
GHISLAINE MAXWELL
1540
$5,259.80
(A) The balance stated for this account is as of 6/16/2020.
UBS FINANCIAL SERVICES INC.
GHISLAINE MAXWELL
BOSTON MA 02114-3252
$5.10
UBS FINANCIAL SERVICES INC.
TERRAMAR PROJECT, INC.
BOSTON MA 02114-3252
$26.43
UBS FINANCIAL SERVICES INC.
MAX FOUNDATION
BOSTON MA 02114-3252
$979.29
UBS FINANCIAL SERVICES INC.
ELLMAX, LLC
BOSTON MA 02114-3252
$0.62
UBS FINANCIAL SERVICES INC.
GHISLAINE MAXWELL IRA
BOSTON MA 02114-3252
$59,039.62
The relationship between Ghislaine Maxwell and the
Montpelier Trust is unknown at this time. It can be inferred
that there is a relationship between Ghislaine Maxwell and
the Montpelier Trust due to the following:
(1) On 6/24/2019, $785,339 and was transferred from
Ghislaine Maxwell's UBS account
0 the UBS
Montpelier Trust account
(2) On 7/2/2020, Ghislaine Maxwell was arrested at
residence located at
Bradford NH. On
12/13/2019, Granite Reality LLC purchased that property in
an all cash transaction for $1,070,800. The address listed for
Granite Reality LLC is
Boston MA 02210-
2698. The address, excluding the ZIP code, is identical to
UBS FINANCIAL SERVICES INC.
MONTPELIER TRUST
BOSTON MA 02210-2698
$4,841,818.09
Montpelier Trust's address.
1
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SUMMARY OF GHISLAINE MAXWELL'S RELATED ACCOUNTS AS OF 6/30/2020 - DRAFT
6/30/2020
ACCOUNT HOLDERS'S
ACCOUNT
BALANCE (IN
FINANCIAL INSTUTITION
ACCOUNT NAME
STATEMENT ADDRESS
NUMBER
USD) (A)
COMMENT
The relationship between Ghislaine Maxwell and the
Montpelier Trust is unknown at this time. It can be inferred
that there is a relationship between Ghislaine Maxwell and
the Montpelier Trust due to the following:
(1) On March 13, 2019, $500,000 was transferred from
Ghislaine Maxwell's UBS account
to the UBS
Montpelier Trust account
(2) On 3/17/2020, $3,560.59 was transferred from the
Montpelier Trust's UBS account
to the USAA
Federal Savings Bank account titled Scott Borgerson Or
Ghislaine Maxwell
(3) On 7/2/2020, Ghislaine Maxwell was arrested at
residence located at
Bradford NH. On
12/13/2019, Granite Reality LLC purchased that property in
an all cash transaction for $1,070,800. The address listed for
Granite Reality LLC is
Boston MA 02210-
2698. The address, excluding the ZIP code, is identical to
UBS FINANCIAL SERVICES INC.
MONTPELIER TRUST
BOSTON MA 02210-2698
$1.46
Montpelier Trust's address.
Source Form 114 ("FBAR") filed on 10/13/19 filed with the
U.S. Treasury Department's Financial Crimes and
Enforcement Network ("FinCEN") on behalf of Ghislaine
Maxwell. The FBAR states that the maximum account value
in 2018 was $1,556,801. The current balance of this account
BARCLAYS
N/A
is unknown.
Source FBAR filed with FinCEN on 10/13/19 filed on behalf
of Ghislaine Maxwell. The FBAR states that the maximum
account value in 2018 was $644,686. The current balance of
BARCLAYS
N/A
this account is unknown.
Source FBAR filed on 10/13/19 filed with FinCEN on behalf
of Ghislaine Maxwell. The FBAR states that the maximum
account value in 2018 was $41,291. The current balance of
BARCLAYS
N/A
this account is unknown.
2
EFTA00020369

=== Page 3 ===
SUMMARY OF GHISLAINE MAXWELL'S RELATED ACCOUNTS AS OF 6/30/2020 - DRAFT
6/30/2020
ACCOUNT HOLDERS'S
ACCOUNT
BALANCE (IN
FINANCIAL INSTUTITION
ACCOUNT NAME
STATEMENT ADDRESS
NUMBER
USD) (A)
COMMENT
Source - FBAR filed on 10/13/19 filed with FinCEN on behalf
of Ghislaine Maxwell. The FBAR states that the maximum
account value in 2018 was $640,205. The current balance of
BARCLAYS
N/A
this account is unknown.
Source - FBAR filed with FinCEN on 10/13/19 filed on behalf
of Ghislaine Maxwell. The FBAR states that the maximum
account value in 2018 was $48,113. The current balance of
WEALTH AT WORK LIMITED
N/A
this account is unknown.
TOTAL
$4,907,130.41
3
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=== Page 1 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 1
DR. KIMBERLY B. MEHLMAN-OROZCO
.
.
www.mehlmanorozco.com
EDUCATION
Doctor of Philosophy
Criminology, Law and Society
George Mason University
Dissertation: The "Crimmigration" Affect: An Analysis of 287(g) and Latino/a Representation in the U.S.
Juvenile Justice System
Expertise: Human Trafficking, Human Smuggling, Immigration, Survey Methods and Systematic Review
Master of Arts
Justice, Law, and Crime Policy
George Mason University
Thesis: Foreign Nationals and Crime: An Exploratory Analysis of Undocumented Migrants in Northern
Virginia
Bachelor of Science
Administration of Justice
George Mason University
Cum Lande
TEACHING EXPERIENCE
Surviving and Thriving Beyond Sex Trafficking SP18
Ph.D. Research Course
Sustainability Education
Prescott College
CRIM307 Social Inequality, Crime, and Justice FA17
Criminology, Law and Society
George Mason University
CRIM405 Law and Justice Around the World
SP17, SP18
Criminology, Law and Society
George Mason University
CRIM308 Human Rights and Justice
FA16
Criminology, Law and Society
George Mason University
CCJS100 Intro to Criminal Justice
FA12-SP14
Department of Criminology & Criminal Justice
University of Maryland College Park
CCJS370 Race and Crime
FA12-SP14
Department of Criminology & Criminal Justice
University of Maryland College Park
CCJS432 Law of Corrections
FA12
Department of Criminology & Criminal Justice
University of Maryland College Park
EFTA00018632

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Curriculum Vitae- October 2020
Mehlman-Orozco 2
CCJS418J Foreign Nationals and Crime
FA12-SP13
Department of Criminology & Criminal Justice
University of Maryland College Park
CRIM490 Foreign Nationals and Crime
SU09, SU10, SU11, SU12
Criminology, Law and Society
George Mason University
GED, Work Place Essential Skills,
and Adult Basic Education
SU05-SU06
Adult Detention Center
Prince William County
RESEARCH EXPERIENCE
CEO
FA19- Present
Break the Chain
Executive Director
WI18- Present
Freedom Light
Partner/Human Trafficking Expert Witness
FA16- WI18
Mahn, Mehlman & Associates
Human Trafficking Subject Matter Expert
SU16-FA17
RAND Corporation
Executive Director/Human Trafficking Consultant
WI12- FA16
The Justitia Institute
Director
FA10 - WI12
Latino Policy Institute
Roger Williams University
Research Associate
SU11 - WI12
Cochrane Collaboration College for Policy
George Mason University
Lead Clinical Trials Search Coordinator
SU10 - WI12
Justice Health Field
The Cochrane Collaboration
Senior Research Associate
SU08 - SU11
OJJDP Census of Juveniles on Probation
George Mason University
Graduate Research Assistant
SU10 - FA10
Violence and Victimization Research Division
National Institute of Justice (On Contract)
Office of Justice Programs
Senior Fellow
SU08 - FA10
The Lloyd Society
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Curriculum Vitae- October 2020
Mehlman-Orozco 3
Graduate Research Assistant
SU06 - SU08
Trinidad & Tobago Crime Reduction Project
George Mason University
Graduate Research Assistant
WI07-SP07, SP08
OJJDP Vaccines for Children Project
George Mason University
PUBLICATIONS
Mehlman-Orozco, Kimberly B. (2019). "Jeffrey Epstein's deal with Alexander Acosta wasn't out of
line with what I have seen." USA Today.
Mehlman-Orozco, Kimberly B. and Sheriff William D. Snyder. (2019). "Robert Kraft spa scandal: Sex
trafficking is hard to prove, that doesn't mean it's a lie." USA Today.
Mehlman-Orozco, Kimberly B. and William D. Snyder. (2019). "Legalizing prostitution could end sex-
trafficking investigations." The Hill.
Mehlman-Orozco, Kimberly B. (2019). "How to Fight Sex Trafficking." Politico.
Mehlman-Orozco, Kimberly B. (2019). The Jihadi Next Door: How ISIS is Forcing, Defrauding, and
Coercing Your Neighbor into Terrorism. SkyHorse.
Mehlman-Orozco, Kimberly B. (2018). "Sex trafficking bill likely to do more harm than good." The
Baltimore Sun.
Mehlman-Orozco, Kimberly B. (2018). "Why cracking down on websites won't stop online sex
trafficking." Thomson Reuters Foundation.
Mehlman-Orozco, Kimberly B. (2018). "Legislation Aiming to Stop Sex Trafficking Would Hurt
Investigations." Homeland Security Today.
Mehlman-Orozco, Kimberly B. (2017). "Trafficking victims get lost under unjust criminal
convictions." The Hill.
Mehlman-Orozco, Kimberly B. (2017). "Projected Heroes and Self-Perceived Manipulators:
Understanding the Duplicitous Identities of Human Traffickers." Trends in Organized Crime.
Mehlman-Orozco, Kimberly B. (2017). Hidden in Plain Sight: America's Slaves of the New
Millennium. ABC-CLIO/Praeger.
Mehlman-Orozco, Kimberly. (2017). "Why we should question the FBI's recent human trafficking
sting." Thomson Reuters.
Mehlman-Orozco, Kimberly. (2017). "Decriminalize sex work to bring trafficking victims out of the
shadows." The Hill.
Mehlman-Orozco, Kimberly. (2017). "Decriminalizing sex work would help bring victims out of the
shadows." The Washington Post.
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Curriculum Vitae- October 2020
Mehlman-Orozco 4
Mehlman-Orozco, Kimberly B. (2017). "Why the Stop Enabling Sex Traffickers Act is the Wrong
Solution." The Crime Report.
Mehlman-Orozco, Kimberly B. (2017). "Identifying Victims of Human Trafficking." Dimensions of
Dental Hygiene.
Syme, Sheryl, Camardese, Susan, and Kimberly Mehlman-Orozco. (2017). "Human Trafficking: Red
Flags for Dental Professionals." Decisions in Dentistry.
Mehlman-Orozco, Kimberly B. (2017). "Vilifying Backpage.com won't help fight sex trafficking" The
Washington Post.
Mehlman-Orozco, Kimberly B. (2017). "Child Trafficking: The Tragedy of "Princess" The Crime Report.
Mehlman-Orozco, Kimberly B. (2017). "To sue or not to sue third-party businesses for sex
trafficking?" Thomson Reuters Foundation.
Mehlman-Orozco, Kimberly B. (2017). "Hunting the Internet's Sex Predators." The Crime Report.
Mehlman-Orozco, Kimberly B. (2017). "Will shutting down Backpage.com end the scourge of child
sex trafficking in America?" Thomson Reuters Foundation.
Mehlman-Orozco, Kimberly B. (2017). "Sex Trafficking: A Surprising Rescue Story." The Crime Report.
Mehlman-Orozco, Kimberly B. (2017). "What every parent should know about sex trafficking."
Baltimore Sun.
Mehlman-Orozco, Kimberly B. and Simon Hedlin. (2017). "Mehlman-Orozco, Hedlin: Stop
criminalizing victims of sex trafficking." The Houston Chronicle.
Mehlman-Orozco, Kimberly B. (2017). "Why Do We Criminalize Young Victims of Sex Trafficking?"
The Crime Report.
Mehlman-Orozco, Kimberly B. (2016). "The Plight of Sex-Trafficking Survivors." The Gay and Lesbian
Review Worldwide.
Mehlman-Orozco, Kimberly B. (2016). "Sex Trafficking is often hidden in plain sight." The Hill.
Mehlman-Orozco, Kimberly B. (2016). "Will Legalized Prostitution End the Sex Trafficking Scourge?"
The Huffington Post.
Mehlman-Orozco, Kimberly B. (2016). "What happens after a human trafficking victim is rescued?"
The Hill.
Mehlman-Orozco, Kimberly B. (2016). "The Reality of Sex Trafficking in Washington's Red Light
District." Baltimore Sun.
Mehlman-Orozco, Kimberly B. (2016). "America's Symbolic, Not Effective, Anti-Trafficking Policy.
Diplomatic Courier.
Mehlman-Orozco, Kimberly B. (2016). America's Anti-Trafficking Efforts: Hollow victories for public
accolade. Connection Newspapers: Chantilly, Centerville, Great Falls, Herndon, McLean, & Vienna.
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=== Page 5 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 5
Mehlman-Orozco, Kimberly B. (2016). "Sex Slaves or Prostitutes?: How Human Trafficking is Hidden
in Plain Sight in America's Capital." Diplomatic Courier.
Mehlman-Orozco, Kimberly B. (2015). "Safe Harbor Legislation for Juvenile Victims of Sex
Trafficking: A Myopic View of Improvements in Practice. Social Inclusion.
Mehlman-Orozco, Kimberly B. (2015). "Tor and the Bitcoin: An Exploration into Law Enforcement
Surveillance Capability Online". Diplomatic Courier.
Mehlman-Orozco, Kimberly B. (2014). "Human Trafficking in the Philippines: A Blemish on
Economic Growth". Diplomatic Courier, Recovery in the Philippines.
Mehlman-Orozco, Kimberly B. (2014). "Devoid of Research: An Evaluation of Human
Trafficking Interventions". Diplomatic Courier, Special Issue: Breaking the Cycle of Human Trafficking.
Martinez, Ramiro, and Mehlman-Orozco, Kimberly B. (2014). "Hispanic Immigration and Crime".
Oxford Handbook of Ethnicity, Crime, and Immigration. Eds. Michael Tonry and Sandra
Bucerius. Oxford University Press.
Mehlman-Orozco, Kimberly B. (Contributing Author) (2010) "Breaking It Down: Justice, Law & Society
Abstracts for Policymakers and Practitioners". Center for Justice Law and Society.
REPORTS
Mehlman-Orozco, Kimberly B. (May, 2017). Expert Witness Report. State of Obio v. Michael Moore. CR
16-3191.
Mehlman-Orozco, Kimberly B. (2011). The Effects of In-State Tuition for Non-Citizens: A Systematic
Review of the Evidence. Latino Policy Institute at Roger Williams University.
http://www.rwu.edu/depository/lpi/Ipi-report.pdf
Mehlman-Orozco, Kimberly B. (2008). Race and Reporting Burglary, Robbery, and Assault in Trinidad
and Tobago. (Completed under a grant from the Trinidad and Tobago Government).
SCHOLARLY PRESENTATIONS
Mehlman-Orozco, Kimberly B. (2019). Keynote Speaker: National Capital Region Threat Intelligence
Consortium (NTIC) Human Trafficking Seminar.
Mehlman-Orozco, Kimberly B. (2019). Law Enforcement's Role in Combating Human Trafficking and
Assisting Victims. Police Executive Research Forum (PERF).
Mehlman-Orozco, Kimberly B. and Marisa Trasatti (2019). Human Trafficking: The Silent Risk. The
RIMS (Risk Management Society) Conference.
Mehlman-Orozco, Kimberly B. (2019). Social Policy and Justice Panelist. Harvard College Project of
Asian and International Relations. Harvard University.
Mehlman-Orozco, Kimberly B. (2018). Women in Homeland Security Human Trafficking Symposium
Panelist. Marymount University.
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=== Page 6 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 6
Mehlman-Orozco, Kimberly B. (2017). Human Trafficking Symposium Panelist. Liberty University
School of Law.
Martin, Favian, Mehlman-Orozco, Kimberly, and Wooditch, Alese. (2014). Mexican Migration to the
United States: An Exploratory Study into Illegal Border Crossings. Academy of Criminal Justice
Sciences. Philadelphia, PA
Mehlman-Orozco, Kimberly B. (2010). "Justice Health Systematic Review Methods," Presented at the
annual colloquium of the Cochrane and Campbell Collaborations: Keystone, CO.
Mehlman-Orozco, Kimberly B. (2010). "Open Access Systematic Reviews for Juvenile Probation
Information," Presented at the first annual OJJDP Probation Summit: Washington, D.C.
Mehlman-Orozco, Kimberly B., Chirieleison, J., Sebold, C. M., Douds, A., Gallagher, A.M., and
Gallagher, C.A. (2010). "Characteristics of Juveniles on Probation: Collecting Data from Atlantic to
Pacific". Presented at the 2010 American Probation and Parole Association Conference: Washington,
D.C.
Mehlman-Orozco, Kimberly B. (2010). "Justice Health Search Methods: PubMed and More," Presented
at the International Network for Justice Health Meeting: Scottsdale, AZ.
Gallagher, C.A., Douds, A.S., Mehlman-Orozco, Kimberly B., Chirieleison, J., and Olaghere, A. (2010).
"Justice Health Bibliographic Data Mapping," Presented at the International Network for Justice
Health Meeting: Scottsdale, AZ.
Mehlman-Orozco, Kimberly B. (2010). "Smuggling and the Likelihood of Detention among
Undocumented Migrants," Law and Society Association Conference: Chicago, IL.
Douds, A.S. and Mehlman-Orozco, Kimberly B. (2010). "FASD in Justice Facilities: What does the
research tell us?", Meeting of the Interagency Coordinating Committee on Fetal Alcohol Spectrum
Disorders: Rockville, MD.
Gallagher, Catherine, Taxman, Faye, Kinner, Stuart, Doyle, Jodie, Pardo-Rengifo, Monica, Mehlman-
Orozco, Kimberly B., Olaghere, Ajima, Royle, Nick, Gabriel Cuervo, Luis. (2009). "Knowledge
mapping for research prioritization: examples from the Network for Justice Health". 17th Cochrane
Colloquium, Singapore.
Mehlman-Orozco, Kimberly B. (2009). "Justice Health Systematic Review Methods," Presented at the
International Network for Justice Health Meeting: Orlando, FL.
Mehlman-Orozco, Kimberly B. (2008). "Foreign Nationals and Crime: An Exploratory Analysis of
Undocumented Migrants in Northern Virginia," American Society of Criminology Conference: St.
Louis, MO.
OTHER PRESENTATIONS
Trasatti, Marisa, Mehlman-Orozco, Kimberly B., Clark, Fran, et. al. (2020). Training to Combat Human
Trafficking at your Commercial Premise- Learn the Emerging Risks, Litigation Issues and
Preventative Measures. Claims and Litigation Management Alliance Conference.
Trasatti, Marisa, Mehlman-Orozco, Kimberly B., Ewing, Lance. (2020). Human Trafficking: The Silent
Risk. Claims and Litigation Management Alliance Conference.
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=== Page 7 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 7
Mehlman-Orozco, Kimberly B. (2018). Invited Trainer on Human Trafficking Provided to the
Advancing the Business of Healthcare Medical Coding Chapter in Woodbridge, Virginia (2 CEUs).
Mehlman-Orozco, Kimberly B. (2018). Invited Trainer on Human Trafficking for the Canadian Police
College Human Trafficking Investigator's Course, Royal Canadian Mounted Police and Halifax
Regional Police, Canada.
Mehlman-Orozco, Kimberly B. (2018). Invited Annual Speaker for the College of Humanities and Social
Sciences Degree Celebration, George Mason University.
Mehlman-Orozco, Kimberly B. (2018). Invited Presenter for the Well Library Honors Event, George
Mason University.
Mehlman-Orozco, Kimberly B. (2017). Invited Training Presentation on Human Trafficking Red Flags
for Prevent Abuse and Neglect through Dental Awareness (P.A.N.D.A).
Mehlman-Orozco, Kimberly B. (2017). Invited Guest Speaker for Human Trafficking Awareness Event
with Kappa Delta Phi International Sorority, George Mason University.
Mehlman-Orozco, Kimberly B. (2017). Invited Guest Speaker at the Mother's Union International
Conference Human Trafficking Forum.
Mehlman-Orozco, Kimberly B. (2017). Invited Guest Speaker at the Keeping Our Youth Safe
Conference. Bernadette's House.
Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker for Girls at High-Risk of Sex Trafficking.
Manassas City Police Department.
Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking. Woodbridge
Woman's Club.
Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker for TEAM Summer Quest: High-Risk
Youth Diversion Program. Manassas City Police Department.
Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking. Soroptimist
International, Alexandria Chapter.
Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking. Republican
Women of Clifton.
Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking in Northern
Virginia. Westminster at Lake Ridge.
Mehlman-Orozco, Kimberly B. (2016). Keynote Speaker. Soroptimist Human Trafficking Awareness
Event.
Mehlman-Orozco, Kimberly B. (2015). Invited Guest Speaker on Human Trafficking. Trinity Episcopal
Church.
Mehlman-Orozco, Kimberly B. (2015). Invited Guest Speaker for TEAM Summer Quest: High-Risk
Youth Diversion Program. Manassas City Police Department.
EFTA00018638

=== Page 8 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 8
Mehlman-Orozco, Kimberly B. (2014). Invited Guest Speaker for TEAM Summer Quest: High-Risk
Youth Diversion Program. Manassas City Police Department.
Mehlman-Orozco, Kimberly B. (2014). Invited Guest Speaker on Mapping Suspected Human
Trafficking Networks through Advertisements. Homeland Security Investigations, DHS, Buffalo,
NY.
Mehlman-Orozco, Kimberly B. (2013). Exhibitor. Governor's Summit on Human Trafficking.
Richmond, VA.
Mehlman-Orozco, Kimberly B. (2013). Invited Guest Speaker on Labor Trafficking. St. Francis of Assisi
Catholic Church.
Mehlman-Orozco, Kimberly B. (2011). Keynote Speaker. First Annual Quetzal Award Gala. Guatemalan
Center of New England.
EXPERT WITNESS CASES-CONSULTATION AND/OR TESTIMONY
Forthcoming
Woodhull Freedom Foundation et al. V. United States.
2019-Present
United States V. Matthew Woods, United States District of New
Mexico
2019
United States V. Adonis Baker, United States District of New
Mexico
2019
United States V. Cornelius Galloway, United States District of New
Mexico
2018
RCMP Federal Serious and Organized Crime R vs. Downey &
Beals C/O Human Trafficking 2016-465660, Halifax, Canada
2018
United States of America vs. Savanah April Via, U.S. District
Court for the District of Arizona
2018
Commonwealth of Virginia V. Corey Cardoza, Henrico County
2018
People V. Kareem Abdur-Razzaaq, Ind. No. 3154/2013, and
People V. Lemuel Skipper, Ind. No. 2409/2015, Bronx County
2017-2020
United States of America V. Miguel Scott Arnold, Terrence
Hawkins, Tevin Bynoe, Emonie Murphy, and Joshua Guity-Nunez,
United States District Court for the Middle District of
Pennsylvania.
2017-2018
Doe V. Subh Properties, et al., Civil Litigation, State of Maryland
2017-2018
State of Ohio V. Michael Moore, Lucas County Court
2017-2018
People of the State of California Plaintiff V. Tracy Sims Superior
Court of California, County of Los Angeles
EFTA00018639

=== Page 9 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 9
2017
Keo Ratha; Sem Kosal; Sophea Bun; Yem Ban; Nakry Phan; and
Sok Sang V. Phatthana Seafood Co., Ltd; S.S. Frozen Food Co.,
Ltd.; Doe Corporations 1-5; Rubicon Resources, LLC; and Wales
& Co. Universe, Ltd. United States District Court for the Central
District of California
2017
In re: REFLEX MEDIA, INC., a Nevada corporation, Claimant,
VS. VIBE MEDIA, INC. d/b/a CityVibe.com, a California
corporation; SOPHIA THOMPSON, an individual;
PEAKRIDGE d/b/a SugarModels.com, an Anguilla company;
DANIEL ROMAN a/k/a Daniel Romanesse, an individual; ALI
ASKARI, an individual; and DOES 1 through 10, inclusive
2016-2017
J.S., S.L., and L.C. V. Village Voice Media Holdings LLC, Supreme
Court of the State of Washington
2016-2017
People of the State of California Plaintiff V. James Joseph, et. Al.
Contra Costa County Court
2016
People of the State of California Plaintiff V. Young Kyung Cho
Superior Court of California, County of Los Angeles
2016
People of the State of California Plaintiff V. Mixon-Givens
Santa Clara County Court
SELECTION OF MEDIA
July 4, 2020
CBS News. Epstein's alleged accomplice Ghislaine Maxwell set to
be arraigned next week.
January 23, 2020
Skift. Opening Closed Doors: Can Hotels Do More to Fight
Human Trafficking?
August 9, 2019
ABC. This Week with George Stephanopoulos. Panel discussion
on Jeffrey Epstein.
July 9, 2019
CBS News. Sex trafficking expert discusses Jeffrey Epstein case
and sexual abuse.
May 10, 2019
Hollywood Reporter. Sex Trafficking mars the Mystique of
Cannes Film Festival.
April 12, 2019
The Hill. Expert says it's 'very unlikely' Robert Kraft prostitution
case would yield human trafficking convictions.
January 11, 2019
The Seattle Times. Documentary puts new attention on R. Kelly
sex allegations.
August 22, 2018
The Crime Report. Backpage Founders: We're Victims of Attack
on Free Speech.
EFTA00018640

=== Page 10 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 10
May 5, 2018
Delaware Online. Human Trafficking Court shut down, to be
merged with other treatment courts in Delaware.
May 1, 2018
Delaware Online. Despite good intentions, Delaware slow to
address human trafficking.
April 24, 2018
ABC. Will new law protect women from sex trafficking?
April 23, 2018
The Ringer. How Sex Ads Became a Battleground for the Future
of the Internet.
April 22, 2018
Miami Herald. He pimped a minor at Santa's Enchanted Forest.
He got slapped with federal prison.
April 13, 2018
Yahoo Lifestyle. Women's March lambasted for criticizing
shutdown of Backpage.com.
April 10, 2018
Miami Herald. Florida's sex industry 'in a panic' after feds shut
down notorious Backpage website.
April 9, 2018
The Crime Report. With Backpage Closed, Where Will The Sex
Slave Trade Go?
March 22, 2018
Washington Post. Bill enabling prosecutors, victims to pursue
websites that host sex traffickers heads to White House.
March 2, 2018
Governing. 3 Cities Lead Fight Against Human Trafficking.
February 1, 2018
Vanity Fair. The Republican Party is Having Another Todd Akin
Fiasco.
February 1, 2018
New York Magazine. Missouri GOP Senate Hopeful Goes Off
the Deep End on the Sexual Revolution and Human Trafficking.
January 31, 2018
Kansas City Star. Josh Hawley blames sex trafficking on 'sexual
revolution' of 1960s in leaked audio.
January 25, 2018
Homeland Security Today. Expert Delves Into Real Face of
Human Trafficking: Victims and Perpetrators.
January 23, 2018
Huffington Post. Study Finds More Than 9,000 Brothels
Masquerading As Legit Businesses.
January 11, 2018
International Business Times. Human trafficking: Why we are all
guilty of supporting the modern slave trade.
January 8, 2018
Majority Report Radio. America's Slaves of the New Millennium
with Dr. Kimberly Mehlman-Orozco.
December 21, 2017
Fast Company. Hotels Are Key In The Fight To End Human
Trafficking.
EFTA00018641

=== Page 11 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 11
December 12, 2017
WNPR. The Colin McEnroe Show. Child Labor In America And
Abroad.
November 4, 2017
C-SPAN. Hidden in Plain Sight Book Talk.
September 22, 2017
Gray Media. Interview by Kyle Midura. Sex Trafficking Internet
Crackdown Proposal.
August 8, 2017
i24 news. Interview for Stateside with David Shuster. Model
allegedly kidnapped for dark web auction.
August 2, 2017
Newsy. Interview for "The Why" on human trafficking on the
Internet.
July 30, 2017
Al Jazeera. Segment Produced by Ruairi Casey. World Day
Against Human Trafficking.
July 25, 2017
Fox News Radio. Interviewed by Eben Brown. "Security
America" segment on human smuggling deaths in San Antonio.
July 25, 2017
Dallas News. Interviewed by Sarah Mervosh. New trick of the sex
trade: Pimps can use retail gift cards to buy Backpage.com ads.
July 24, 2017
WJLA. Interviewed by Stephen Loiaconi. Human smuggling
deaths underscore need for immigration reform, experts say.
July 18, 2017
The Washington Post. Interviewed by Tom Jackman. Under
attack, Backpage.com has its supporters as anti-trafficking tool.
But many differ.
June 11, 2017
PJ Media. Interviewed by Karl Herchenroeder. Expert Notes Gap
in Human-Trafficking Laws as Senators Press for Fund Renewal.
April 19, 2017
WYPR. Interviewed by Tom Hall. Misinformation Sparked
#DCMissingGirls Outrage, But It Highlights Real And
Overlooked Issues.
March 30, 2017
CBS. Interviewed by Jennifer Earl. Mom's warning about "human
trafficking" at IKEA goes viral; what you need to know.
March 29, 2017
Women's Health. Interviewed by Korin Miller. This Mom Claims
She Encountered Human Traffickers At IKEA And People Are
Freaking Out.
February 10, 2017
Miami Herald. Interviewed by David Ovalle. Florida lawsuit
targets website decried as hub for human trafficking.
February 3, 2017
Miami Herald. Interviewed by David Ovalle. The 'adult' section
might be closed but Miami sex workers still on the job.
EFTA00018642

=== Page 12 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 12
January 1, 2017
OutSmart Magazine. Interviewed by Dr. Laura McGuire on
Human Trafficking. Hidden in Plain Sight: Researcher Dr.
Mehlman-Orozco Discusses the Realities of Human Trafficking.
February 3, 2015
NBC. Interviewed by Tracy Connor. Shoe Bomber has "Tactical
Regrets' Over Failed American Airlines Plot.
January 19, 2015
CNN. Interviewed by Pam Brown. 'Jihad Jane' moved by 'love'
and feminine 'pride.'
August 15, 2013
USA Today, Interviewed by Yamiche Alcindor. Dozens of States
Pass Laws to Fight Human Trafficking.
June 6, 2013
USA Today. Interviewed by Yamiche Alcindor. Blue Campaign by
DHS aims to combat human trafficking.
August 12, 2012
Fox 5 News (DC/MD/VA). Television interview on in-state
tuition report on Maryland. Interview by reporter Shawn Yancy.
May 18, 2011
Chronicle of Higher Education. Interviewed for an in-state tuition
story by Katherine Mangan, "In-State Tuition for Illegal
Immigrants Can Be a Plus for Both States and Students."
March 24, 2011
NBC 10 (RI). Television interview on Latino population growth,
"Digging Deeper: Hispanics on the Rise."
February 18, 2011
The Yale Herald. Interviewed for a story on racial profiling against
immigrants by police. Story by Lucas Iberico-Lozada, "East
Haven Police Accused of Brutality, Racism."
June 2, 2010
Style Weekly. Interviewed for a human trafficking story by Peter
Galuszka, "The New Slavery: Virginia becomes haven for human
trafficking."
OTHER PROFESSIONAL TRAINING
Transportation Industry Against Human Trafficking
U.S. Department of Commerce
Fall 2020
Presentation
"Freedom Together" D.C., M.D., and V.A. Regional
D.C., M.D., and V.A. Task Forces
Anti Human Trafficking Task Force Conference
Spring 2018
Conference
Virginia Forum on Human Trafficking
Dept. of Criminal Justice Services
Fall 2015
Conference
Regional Conference of Human Trafficking
Task Forces
DMV Anti-Trafficking Working
Fall 2015
Conference
Group
Maryland Freedom Conference
Towson University
Winter 2015
Conference
EFTA00018643

=== Page 13 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 13
Sharing Lessons, Sharing Responsibility:
Combating Human Trafficking
Migration Policy Institute
Spring 2013
Conference
Freedom Network Annual Conference
Freedom Network
Spring 2013
Conference
Human Trafficking Panel Discussion
George Washington Law
Spring 2013
Working Group
Analytic Statistics and Meta Analysis
Stata
Spring 2011
Paid Training
Systematic Review and Meta Analysis
GMU
Spring 2009, Fall 2010
Independent Graduate Study
PubMed, NLMGateway, ToxNet and ClinicalTrials.gov
National Library of Medicine
Summer 2009
Search Certifications
Ovid, ProQuest, and Web searches
AHRQ
Summer 2009
Search Certifications
Introduction to ArcGIS Workshops
George Mason University
Fall 2009-Summer 2010
Hand Searching Systematic Review Workshop
Cochrane Collaboration
Fall 2009
Search Certifications
AWARDS
Independent Publisher Award, 2019
Silver Medal for Current Events (Jihadi Next Door).
Independent Publisher Award, 2018
Bronze Medal for Social Issues/Humanitarian (Hidden in Plain
Sight: America's Slaves of the New Millennium).
Dissertation Completion Award, 2012
George Mason University, College of Humanities and Social
Sciences.
Deans Challenge, 2009
George Mason University, College of Humanities and Social
Sciences.
SERVICE
Reviewer
Justice Quarterly, WI18-Present
Advisory Board Member
Empower Her Network, FA17-Present
Survey Methodologist Advisor
United Against Slavery, FA17-Present
Advisory Board Member
Dressember (Anti-trafficking foundation), SP17-Present
Panel of Expert Witnesses
Los Angeles Superior Court, WI17-Present
EFTA00018644

=== Page 14 ===
Curriculum Vitae- October 2020
Mehlman-Orozco 14
Member
Prince William County Human Trafficking Task Force, SU13-
Present
Member
Prince George's County Human Trafficking Task Force, SU12-
Present
Reviewer
Journal of Human Trafficking, FA2014-Present
Member and Former President
Soroptimist International of Woodbridge, FA15-SP18
Reviewer
American Journal of Evaluation, FA2014-FA2015
Member
Prince George's County Human Trafficking Task Force, SU13-
2015
Reviewer
Columbia University Press, FA2013
President and Founding Officer
Student Center for Immigration Research, George Mason
University, FA08 - FA10
Member
Criminology, Law & Society Student Association, George Mason
University, FA09 - WI12
Volunteer
Prince William County Jail, Classification Department, 500 hours,
SP 2005
PROFESSIONAL MEMBERSHIP
National Society for Collegiate Scholars
Phi-Alpha Delta Pre-Law Fraternity
Alpha Chi Honors Fraternity
American Society of Criminology
National Criminal Justice Honors Fraternity
Alpha Phi Sigma Honors Society
EFTA00018645


c1: EFTA00018282
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018282.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(IMD) (FBI)"
Cc:
)"
=
(NY) (FBI)"
(NYPD)"
(USANYS)"
Subject: Re: Epstein investigation
Date: Mon, 26 Oct 2020 21:46:16 +0000
Hi
,
Thanks very much for looking into this, we appreciate it.
Best,
Sent from my iPhone
On Oct 26, 2020, at 3:57 PM,
(IMD) (FBI)
wrote:
Good afternoon AUSA
My apologies for the delay. I'm looking into this matter. Waiting for a response from the FOIA team that process
media. I should have a response shortly.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
)
Confidentiality Statement: This message is transmitted to you by the Litigation Support Unit of the FBI's
Information Management Division. This message, along with any attachments, may be confidential, law
enforcement sensitive, and legally privileged. If you are not the intended recipient of this message, please
destroy it without further retention or dissemination (unless otherwise required by law). Please notify the
sender of the error by separate e-mail or by calling (540) 868-4843.
From:
)
Sent: Monday, October 26, 2020 3:41 PM
To:
(IMD) (FBI)
Cc:
)
>;
(NY) (FBI)
is
(NYPD)
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein investigation
Hi
EFTA00018282

=== Page 2 ===
Just following up on this, thanks. Any information you could provide would be very helpful.
Thanks,
From:
Sent: Monday, October 19, 2020 6:34 PM
To:
(IMD) (FBI)
Cc:
is
(NY) (FBI)
is
>;
(USANYS)
Subject: RE: Epstein investigation
Hi
Hope you're doing well. As our team
reviewing these materials in connection with discovery, we wanted to follow up
with you about this project. In particular, we were hoping you could tell us how your office approached CDs that were in
the boxes of materials from Florida. We noticed in the scans we received some documents that looked like the attached
file - which looks like a photocopy of the CD. Were those materials downloaded by your office? If not, no worries at all,
we have them from the primary file, but we wanted to check with you to make sure we had the complete set of
materials you sent.
Thanks very much,
From:
Sent: Wednesday, February 13, 2019 9:53 AM
To:
(IMD) (FBI)
Cc:
is
(USANYS)
is
(NY) (FBI)
y.
Subject: RE: Epstein investigation
Hi
Wanted to quickly check in to follow up on our conversations last week and earlier this week - I think you were able to
transmit the scanned records to
but I'm not sure whether that was just the 16,000 pages you mentioned when
we last spoke, or if you were able to get all 29,000 to her? And we're also hoping to confirm for sure that all the
materials you received were definitely scanned in, and to get an index or catalog of those materials (including what
media was included).
Another person on our team,
who's copied,
jumping in to coordinate on this, so if it's easier to chat via
phone her number
,
and please let us know if anything would be helpful on our end.
thanks again!
From:
)
Sent: Wednesday, January 30, 2019 17:19
To:
(IMD) (FBI)
Cc:
is
(USANYS)
is
EFTA00018283

=== Page 3 ===
(NY) (FBI)
>;
Subject: RE: Epstein investigation
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact
info - I'm reachable at this email address or by phone at
(office) or
(cell). Please don't
hesitate to reach out anytime day or night if we can provide any useful info, or if you have any questions at all, and we
appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for
Friday or early next week to check in on the questions we had, and thanks very much for your help.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00018284


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From:
(USANYE)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Date: Wed, 21 Aug 2019 20:17:07 +0000
You're all set! Good luck. And please just keep me posted, since I'm going to be stuck writing his Capital Case memo this
fall!
From:
(USANYS)
Sent: Tuesday, August 20, 2019 4:59 PM
To:
(USANYE)
Cc:
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
Thanks! If you're good with it, we'll reach out, copying you, to set up a proffer within the next week or so. Copying
who's also working on this.
From:
(USANYE)
Sent: Tuesday, August 20, 2019 4:46 PM
To:
(USANYS)
Subject: RE: Johnny Contreras - Investigation of Jeffrey Epstein Death
The attorney proffer from Andy Patel was today (08/20) at approx. 3:30 pm, just FYI.
From:
(USANYE)
Sent: Tuesday, August 20, 2019 4:34 PM
To:
(USANYS)
Subject: FW: Johnny Contreras - Investigation of Jeffrey Epstein Death
From: Andrew Patel
Sent: Monday, August 12, 2019 3:15 PM
To:
(USANYE)
is
(USANYE)
(USANYE)
Cc: Donald Yannella
(
>; 'Jill Shellow'
;
Andrew Patel
Subject: Johnny Contreras - Investigation of Jeffrey Epstein Death
Dear
This email concerns the investigation into the death of Jeffrey Epstein in
the MCC. We realize that it is unlikely your office is involved, but we
EFTA00018957

=== Page 2 ===
thought that we should inform the government of the following so you can
take whatever action you believe is appropriate.
Jhonny Contreras was recently returned to the SHU in the MCC. At the
time of Mr. Epstein's death, it is my understanding that Mr. Contreras was
housed in a cell on the same tier and across the hall from Mr. Epstein's
cell. Mr. Contreras did not see Mr. Epstein hang himself, but he would be
willing to speak to investigators, in the presence of counsel, about his
observations.
Please let us know if there is anything further we should do to follow-up.
Andy
Andrew G. Patel
Attorney at Law
80 Broad Street, Suite 1900
New York, NY 10004
Tel:
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended
only for the use of the individual or entity named above. If the reader of this message is not the intended recipient,
or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination, distribution or copying of the communication is strictly prohibited. If you have received this e-mail in
error, please notify me immediately by telephone at
and by return e-mail, and delete all copies of the
message from your computer. Thank you.
EFTA00018958


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From: Bruce Barket <b
To:
)"
Cc:
(USANYS)"
Aida Leisenring
"
>, Michael Bachrach
Subject: Re: Tartaglione questioning
Date: Mon, 12 Aug 2019 16:03:55 +0000
Thank you.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
Barket Epstein.com
> On Aug 12, 2019, at 12:01 PM,
)
wrote:
>
> Received. Jason and I are not involved in the investigation into Mr. Epstein's death, but I will forward your
email to the AUSAs who are working on that particular investigation.
>
> Best,
> Maurene
>
>
>
V
>
Assistant United States Attorney
>
Southern District of New York
>
V
V
V
>
V
Original Message
V
From: Bruce Barket <bbarket@barketepstein.com>
> Sent: Monday, August 12, 2019 7:47 AM
> To:
;
(USANYS)
>; ; Aida Leisenring <aleisenring@barketepstein.com>; tonyricco
<tonyricco@aol.com>; bkoffsky@snet.net; Michael Bachrach <michael@mbachlaw.com>;
i
>
Subject: Tartaglione questioning
V
>
Good morning,
V
V
Given that there are apparently two (the FBI and the IG) investigations into Mr Epstein's suicide, I am writing
EFTA00020127

=== Page 2 ===
to remind everyone that Mr. Tartaglione should not be questioned by anyone about any matter without my prior
knowledge and consent.
V
> I am not precluding his cooperation with the investigations, but I want to be sure he is not questioned without
counsel's knowledge and consent. Feel free to give my contact information to the relevant investigators.
>
> Bruce Barket
> Barket, Epstein, Kearon, Aldea & LoTurco
> Barket Epstein.com
EFTA00020128


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein Finances
Date: Thu, 18 Jul 2019 18:41:27 +0000
Something prompt this?
From:
(USANYS)
Sent: Thursday, July 18, 2019 2:41 PM
To:
is
-
is
Cc:
(USANYS)
Subject: Epstein Finances
If any of you have 5-10 minutes this afternoon, swing by.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00018383


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=== Page 1 ===
From:
To:
Subject: Fwd: 12/04/09
vs Epstein Deposition Transcript
Date: Wed, 09 Sep 2020 13:52:56 +0000
Attachments: ATT00001.htm; ATT00002.htm;
pdf; ATT00003.htm
Inline-Images: image003.jpg; image002.png
The email exchange below confirms our inability to locate the first volume of
deposition. However,
attached are fairly detailed notes of Paralegal/Investigator
,
who attended the deposition and
recorded these notes contemporaneously.
appears to have held nothing back, and the notes certainly
paint a picture of the kind of troubled young women who were particularly susceptible to Epstein's pattern of
recruitment, grooming and victimization.
Sent from my iPad
Begin forwarded message:
From: "Chris R. Rodgers"
Date: September 8, 2020 at 3:30:51 PM EDT
To: Jack Scarola
Cc: Mary McCann
"Wendy P. Calvet"
Subject: FW: 12/04/09
VS Epstein Deposition Transcript
Jack, below is the "Unable to locate" response from Prose Court Reporting. Visual Evidence, the videography
service used, also confirmed on Friday that a copy of the video is no longer available. I have attached
notes from that deposition.
From:
Sent: September 7, 2020 7:03 AM
To:
Subject: RE: 12/04/09
vs Epstein Deposition Transcript
,
I have searched our records and archives and I am unable to locate Volume I of this deposition from
2009.
Sincerely,
| Privileged and Confidential | Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
EFTA00019605

=== Page 2 ===
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.
PROSE
COURT REPORTING&
LEGAL VIDEO SERVICES
SEARCY
Senior Litigation Paralegal/Investigator
Best Lawyers
DENNEY
SCAROLA
BEST
BARNHART
SHIPLEY
LAW FIRMS
Americancy at Lew
U.S.News
Passion
for Justive
Searcy Denney Scarola Barnhart & Shipley P.A.
2018
www.searcylaw.com
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
EFTA00019606


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=== Page 1 ===
From:
To:
(USAFLS)"
Subject: Re: PRIVATE & CONFIDENTIAL
Date: Fri, 18 Jun 2010 00:04:54 +0000
Importance: Normal
Hey
I confirmed with
that
n Orlando until Monday.
st emailed me. She's been on sick leave for the past couple of days. She's feeling better and is scheduled to be on
annual leave until Tues for Father's Day plans. She said she could make it to the sentencing if you need her there.
I told her I'd relay this to you.
Thanks,
From:
C. (USAFLS)
<
>
To:
Sent: Thu Jun 17 16:04:59 2010
Subject: FW: PRIVATE & CONFIDENTIAL
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From:
(USAFLS)
Sent: Thursday, June 17, 2010 3:52 PM
To:
Cc:
Subject: FW: PRIVATE & CONFIDENTIAL
Hopefully you had a good trip. I assume we cannot answer any of these questions, but please let us know. Thanks.
From:
Sent: Thursday, June 17, 2010 3:49 PM
Subject: PRIVATE & CONFIDENTIAL
Thank you for calling me today. I am confused about certain legal issues. When I asked
this
morning why Jeffrey Epstein was not charged with child sex trafficking given the 2000 TVPA federal laws, she
EFTA00019173

=== Page 2 ===
did not want to respond. It S an important question that merits a substantial answer.
In light of the arguments surrounding the case I would like to know:
1. Why was Jeffrey Epstein allowed to plead guilty to a single count of solicitation of minors to engage in
prostitution?
2. In light of the 5 trafficking offenses outlined on pages 1 & 2 of the NPA signed 10/29/07, why was Epstein
given a twelve (12) months and six (6) months in a county jail (he served only 13 months), for all charges
without adjudication or sentencing, and without probation or community control?
3. Unlike any other registered sex offender in the U.S. prison system today why didn't he serve time in a State
penitentiary? Why was Epstein placed in a solitary cell at the West Palm Beach Stockade and only part time?
Why was he allowed to go to "work" outside of prison for 13 months during the entire day?
4. Why didn't Epstein like all other registered sex offenders in the U.S. have an attached electronic monitor
during his house confinement?
5. Why was prosecution for the offenses deferred in favor of prosecution by the State of Florida?
6. In the ADDENDUM to the NPA (7A-C), Epstein is given the right to select and approve independent third
party counselors for the victims. Why?
According to the NPA signed by MV there are 5 federal trafficking offenses. Why were they dismissed or
deferred?
8. Why is Epstein given the right to contest damages up to an amount agreed to between the victims and Epstein?
9. Esptein's signature on NPA "is not to be construed as an admission of civil or criminal liability or a waiver
of..." Please explain. Why?
10. What was the "gain time" Epstein earned during his period of incarceration?
11. Why would the NPA not be part of a public record? And why would the US have to provide notice to Epstein
before making disclosure under a FOIA request?
12. Why was the Federal Grand Jury investigation suspended?
13. Why the the US agree not to institute any criminal charges against his co conspirators Ghislaine Maxwell,
n light of the evidence?
14. Why are the grand jury subpoenas going to be withdrawn at the completion of the terms of the NPA? given
that he is a registered sex offender and that most probably he will commit the crimes shortly after his release next
month (this assumption based on empirical and medical data obtained from registered sex offenders), there
seems to be no protection mechanism for the victims in place?
15. Why was JE allowed to choose the attorney's for the victims and put a cap on their restitution?
16. Why was the Federal investigation stopped by the USAG?
17. Why hasn't Epstein been rearrested given the 11+ parole violations reported to the parole board since his
home confinement including weekly trips to NY and helicpter ride to travel only 9 miles?
Sincerely,
EFTA00019174

=== Page 3 ===
The message and any attachment may be confidential or privileged and is
intended only for the individual or entity identified above as the
addressee. If you are not the addressee, or if this message has been
addressed to you in error, you are not authorized to read, copy or
distribute this message or any attachments and we ask that you please delete
this message and any attachments and notify the sender by return email.
Delivery of this message and any attachments to any person (s) is not
intended in any way to waive confidentially or a privilege.
EFTA00019175


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From:
(USANYS)"
To:
)"
(USANYS)"
)"
Subject: Bail Oppo Draft
Date: Fri, 05 Nov 2021 18:14:16 +0000
Attachments: Bail_Oppo_v1.docx
Submitted for your review! (I saved this locally on my comp, so I wouldn't mess up your shared organization)
Southern District of New York
Office:
Cell
Email:
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From:
)"
To:
)"
(USANYS)"
)"
Subject: FW: Maxwell superseder prosecution memo
Date: Wed, 24 Mar 2021 03:11:46 +0000
Attachments: Maxwell_S2_Indictment_v1.docx
Wanted to get this to the chiefs today to expedite review, but obviously welcome any thoughts or comments from you
guys. I based the new language primarily on the language from our past Epstein and Maxwell indictments, so hopefully
nothing too controversial.
From:
Sent: Tuesday, March 23, 2021 11:10 PM
To:
(USANYS)
is
is
(USANYS)
>;
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Attached is a draft superseding indictment.
Thanks,
From:
Sent: Tuesday, March 23, 2021 11:29 AM
To:
(USANYS)
is
V.
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Sure thing, will aim to get you a draft today, thanks.
From:
(USANYS)
Sent: Tuesday, March 23, 2021 10:32 AM
To:
is
is
(USANYS)
is
)
Cc:
(USANYS)
Subject: FW: Maxwell superseder prosecution memo
Hi team, we have asked
what the Brass wants to do in terms of review/meeting, and will let you know. In the
meantime and mindful of the Monday GJ date, do you mind putting together a draft indictment for us to review? Thanks!
From:
(USANYS)
Sent: Friday, March 19, 2021 3:34 PM
To:
is
(USANYS)
i
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
is
(USANYS)
is
Subject: RE: Maxwell superseder prosecution memo
EFTA00020331

=== Page 2 ===
Thanks,
From:
)
Sent: Friday, March 19, 2021 3:24 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
is
(USANYS)
is
)
Subject: Maxwell superseder prosecution memo
All,
Attached please find a prosecution memorandum requesting authorization to seek a superseding indictment charging
Maxwell with additional criminal offenses. For reference, I have also attached the two prior prosecution memos regarding
the original indictment in this case. We have tentatively scheduled grand jury time for Monday, March 29th.
Thanks,
EFTA00020332


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From:
)"
To:
(USANYS)"
Subject: Automatic reply: Epstein report
Date: Fri, 13 Dec 2019 22:04:32 +0000
I am currently traveling for work. Although I have some access to emails, my responses may be delayed. For urgent matters, please contact the
other AUSA(s) on the case.
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From
To
Subject: RE: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 01:55:55 +0000
Thank you,
From:
Sent: Sunday, November 28, 2021 3:46 PM
To:
Cc
Subject: RE: United States V. Ghislaine Maxwell
opens
Good luck, guys!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: RE: OPR Epstein Final Report
Date: Mon, 01 Feb 2021 01:35:39 +0000
Thanks so much.
From:
Sent: Sunday, January 31, 2021 8:08 PM
To:
Subject: Re: OPR Epstein Final Report
Let's shoot for the 1-2 window. l'll stand by during that time.
Sent from my iPhone
On Jan 31, 2021, at 6:42 PM,
wrote:
Hi
- With apologies I now have a childcare issue in the morning. Any chance we could chat in the afternoon
instead? I could do anything from 1-2 or after 3. Just let me know if anything in either window works for you. Thanks,
and apologies for the late change -
Sent from my iPhone
On Jan 29, 2021, at 5:55 PM,
wrote:
Of course. Why don't you call me
(
)
at your convenience around 9:30 am? If another time works better,
just let me know.
From:
Sent: Friday, January 29, 2021 5:33 PM
To:
Cc:
Subject: Re: OPR Epstein Final Report
Hi
- I hope this finds you well. Do you have some time to connect early next week on this matter? If there's a
good time Monday morning, in particular, please let us know. Thanks,
Sent from my iPhone
On Nov 12, 2020, at 10:06 AM,
wrote:
Attached please find OPR's final Report in the Jeffrey Epstein matter, and a transmittal letter.
<OPR-#458587-v1-Epstein_Report_transmittal_to_SDNY_(letter_signed).PDF>
EFTA00017958

=== Page 2 ===
<OPR-#458557-v1-Epstein_Report_of_Investigation_and_Exhibits_pdfPDF>
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From:
(USANYS) [Contractor]"
To:
(USANYS)"
)"
Subject: letters to MDC
Date: Mon, 11 Oct 2021 21:44:48 +0000
Attachments: 2021.10.11 MDC - Maxwell_MAIN.docx; 2021.10.11_MDC_ -
Maxwell_PASSWORD.docx
Draft letters to MDC are attached for your review - thanks! One drive to go!!!!!
Saved here:
11
Cover Letters\To
Maxwell
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00020102


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Subject: US V. Maxwell - Government Opposition to Rule 412 Motion
Date: Tue, 02 Nov 2021 03:52:07 +0000
Attachments: Government_412_Opp_[final].pdf
Dear
Attached please find the Government's opposition to the defendant's Rule 412 motion.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: GM discovery
Date: Tue, 27 Oct 2020 21:02:36 +0000
Attachments: 2019.07.31_Epstein_Discovery_Letter.docx
In our first discovery letter to Jeffrey Epstein (attached) we made several disclosures about certain witness statements -
you might remember when we discussed this way back then. In an abundance of caution, we'd like to also provide
Maxwell with one of these statements in particular (the third in the letter). The text is copied here:
During the Palm Beach Department's investigation of the defendant in 2005, a witness ("Witness-1")
disclosed to detectives that the defendant had paid Witness-1 to bring girls for sexualized massages, and
that the defendant told her: "the younger the better." Witness-1 described bringing multiple girls who
were under the age of eighteen to the defendant's residence in Florida. Witness-1 recalled bringing a girl
who was over eighteen, and that the defendant told Witness-1 that this girl was too old. Witness-1
remarked of the defendant: "He likes the girls that are between the ages of 18 and 20." Witness-1 is
represented by Rita Glavin, Esq.
For context, this witness is
and she interacted with Epstein in the early 2000s. This statement occurred in a
videotaped interview with Palm Beach PD. Is it okay with you if we provide this same disclosure in a letter to Maxwell (or
a stand-alone letter, if you prefer)? Please let us know if you'd prefer that we take a different approach, and of course
and
and I are happy to discuss if a call is easier.
Thanks,
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From:
To:
)"1
Subject: Auto Response: Automatic reply: Epstein report
Date: Fri, 13 Dec 2019 20:50:37 +0000
I will be out of the office until Monday, January 13, 2020. If you need immediate assistance please call
at
Otherwise, I will respond to your email upon my return.
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From:
To:
Cc:
Subject: RE: Application for Amended SW
Date: Thu, 22 Oct 2020 17:22:54 +0000
On this same subject, since I spoke with you this morning, I have also had a call with
about this, so our agents are
now aware of the issue. I think you also asked about the status of the image review:
said it's underway and they
understand it needs to be completed by the deadline.
Thanks very much for your guidance on this - if you have any other questions before you speak with
or if any
additional information would be useful, please let us know.
Thanks,
From:
Sent: Thursday, October 22, 2020 1:07 PM
To:
Cc:
Subject: Application for Amended SW
Chiefs,
Thanks very much for talking this morning. As discussed, attached is a draft application for an amended search warrant
correcting the FBI barcode numbers for 3 devices that were seized from Epstein's NY residence. In case it's useful, I'm also
attaching the exhibits that are referenced in the draft application.
Thanks,
EFTA00017800


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=== Page 1 ===
From:
Subject: FW: Epstein Update
Date: Wed, 15 May 2019 14:33:41 +0000
Importance: Normal
Attachments: 2019-05-10_JE_status_memo_for_ODAG.finaldocx.pdf
FYI,
This was delayed a day or two-I was waiting to hear back from Iris on addressees and she finally answered by email this
morning.
From:
Sent: Wednesday, May 15, 2019 10:32 AM
To:
Subject: Epstein Update
Attached is an update on the progress of the Epstein investigation. Please keep this memo on close hold given the
sensitivity of the matter and our effort remain covert.
Feel free to let us know if you have any questions.
Regards,
EFTA00019895


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=== Page 1 ===
From:
To:
Subject: US V. Epstein (SW database)
Date: Wed, 04 Nov 2020 16:53:55 +0000
Inline-Images: image001.png
Hello,
The vendor had to break up the production into seven parts. As of right now the vendor has finished parts 1 - 3 and is
about to start on the stamping of documents for part 4. The vendor has exported part one to the hard drive and is
currently working on exporting part to two the hard drive right now. Part three just finished about 10 minutes ago and
the export has not started yet. You can review the productions by going to the following searches:
SDNY_PROD015 - PART 01
SDNY_PROD015 - PART 02
SDNY_PROD015 - PART 03
If there are any questions please let me know.
Thank you.
EFTA00018161


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=== Page 1 ===
From:
To:
Subject: FW: 21-770 United States of America V. Maxwell "Case FILED"
Date: Tue, 30 Mar 2021 02:10:26 +0000
We received this new appeal in a case of yours. Could you please file a notice of appearance as additional counsel as soon
as possible? Below is a link to the model:
<\\usa.doj.gov\district\NYS\StAndrews\Common\Forms Library\criminal\forms\Appeal\Notice of Appearance for
Substitute, Additional, or Amicus Counsel where WSS lead (model).pdf>
Thanks!
From: cmecf@ca2.uscourts.gov <cmecf@ca2.uscourts.gov>
Sent: Monday, March 29, 2021 4:46 PM
To:
Subject: 21-770 United States of America V. Maxwell "Case FILED"
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of
record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents
filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other
users. To avoid later charges, download a copy of each document during this first viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was entered on 03/29/2021 at 4:43:55 PM EDT and filed on 03/24/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
NOTICE OF CRIMINAL APPEAL, with district court docket, on behalf of Appellant Ghislaine Maxwell,
FILED. [3065965] [21-770]
Notice will be electronically mailed to:
EFTA00019086

=== Page 2 ===
Ms. Bobbi C. Sternheim, -:
The following document(s) are associated with this transaction:
Document Description: Criminal_Docketing_Notice
Original Filename:
/opt/ACECF/live/forms/TammyTorres_21770_3065965_Criminal_Docketing_Notice_141.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=03/24/2021] [FileNumber=3065965-1]
[399ce51145f2d428a570cf09fd26442ed40c3512b85e7ae797a4aa00d6aebb7025e7e27a1d7524a8ce4f061b6d4fc3
8f203d1c440c5455e9464a87aa158815f5]]
Recipients:
Ms. Bobbi C. Sternheim,
Document Description: Case FILED
Original Filename: 21-770.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=03/24/2021] [FileNumber=3065965-0]
[954acf599f19f9d924d7d2aa1040966eec430830a0b1a08e9d7cae1eb07ce280eb42773dfc2fda55c60de7d1bf61cf4b184e6
a315943b11b3b5216a1f21ea581|]
EFTA00019087


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 11, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Pursuant to Judge Nathan's Order of September 3, 2021 (Dkt. No. 335), the Government
writes to inform you that it may refer at trial to the following individuals as co-conspirators of the
defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E):
Jeffrey Epstein
formerly known as
The Government has produced all co-conspirator statements which it intends to offer at
trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government's production today or in its previous
productions. To the extent the Government learns of additional co-conspirator statements as it
continues to prepare for trial, it will produce those statements in connection with its ongoing
obligation to produce Jencks Act material.
EFTA00020105

=== Page 2 ===
Page 2
Please be advised that the above list is limited to the individuals the Government may refer
to as co-conspirators at trial. While the Government makes no representations as to whether it
views other individuals as potential or actual co-conspirators of the defendant, it does not intend
to refer to any other individuals as co-conspirators at trial. The above list is also not intended to
reflect a complete list of individuals who may be referenced at trial. That information is contained
in the Government's Jencks Act production(s).
Please note that this letter and the information contained herein is governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential" under the
Protective Order.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
EFTA00020106


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Request to Modify Protective
Order (Under Seal)]
Date: Tue, 18 Aug 2020 01:24:24 +0000
Attachments: 2020.08.17_JSP_Ltr_re._Modification_of_the_Protective_Order.pdf;
2020.08.17_JSP_Rule_16.1_Affidavit.pdf;Ex_1.pdf;Ex_2pdf;Ex_3pdf;Ex_4.pdf
Ex5.pdf,Ex._6.pdf,Ex._7.pdf; Ex_8.pdf; Ex_9.pdf; Ex_10.pdf
Inline-Images: image001.jpg
From: Nicole Simmons
Sent: Monday, August 17, 2020 8:01 PM
To:
Cc: Jeff Pagliuca
>; Laura Menninger
>; Ann Lundberg
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Request to Modify Protective Order (Under Seal)]
Dear Judge Nathan,
At the request of Jeffrey S. Pagliuca, please see attached Ms. Maxwell's Letter Motion, Affidavit, and accompanying
exhibits filed under seal today August 17, 2020.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
80203
EFTA00018748


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=== Page 1 ===
From:
To:
Subject: Final Voucher 11061409-1(1) has received final approval
Date: Tue, 24 Mar 2020 15:53:20 +0000
Importance: Normal
Dear
Final voucher 11061409-1(1) has received final approval.
Trip ID: 11061409-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name:
Purpose: R20NYS13400 - Epstein Investigation Witness interviews
Destination:
United States
,
Dates: 2020-02-26 - 2020-02-29
Current status: Voucher Awaiting Payment
Voucher total expenses: 1196.11
Estimated trip cost: 1634.37
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# V0008
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.
EFTA00019431


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10893150 approved by
, now awaiting further
approval
Date: Fri, 13 Dec 2019 17:47:44 +0000
Importance: Normal
Dear
Travel authorization 10893150 has been approved by
, now awaiting further approval.
Trip ID: 10893150
Traveler name:
Purpose: R20NYS13257 - U.S. V. Epstein - Witness Interviews
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):
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.
EFTA00019843


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS)"
i
(USANYS)"
Subject: FW: Filing
Date: Fri, 12 Jul 2019 21:30:42 +0000
Importance: Normal
Attachments:2019-07-12,_JE_government_opposition_to_bail_motion_(with_exhibits).pdf,2019-07-
12_JE_government_opposition_to_bail_motion_(without_exhibits).pdf
With exhibits and without.
From:
)
Sent: Friday, July 12, 2019 17:27
To:
is
(USANYS)
is
(USANYS)
Cc:
Subject: RE: Filing
Just a few last-last-minute edits : ) All filed, and attached for records.
From:
)
Sent: Friday, July 12, 2019 17:23
To:
(USANYS)
is
(USANYS)
Cc:
)
is
)
Subject: Filing
I'm logged on remotely while waiting for my flight and am happy to file the bail reply letter if the final version is ready and
is still tied up.
Assistant United States Attorney
Southern District of New York
EFTA00018271


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=== Page 1 ===
Kalamata
Billington Lane
Derrington
Stafford
ST18 9LR
23 Feb 2020
To:
Mel Stride - Chairman of the UK Treasury Select Committee
Copies To:
Federal Bureau of Intelligence
Dame Elizabeth Gloster
The Press
Bailey and the TSC Suppressing Key Information to the FBI, PRA, and FCA Regarding the
Jes Staley JP Morgan Emails
Dear Mr Stride,
I believe you should have an email from me sent to yourself in particular, and copied to
members of the Treasury Select Committee on the 22nd of December 2019. I received a reply a
month later from Maciej Wenerski who handled it as a FOIA, with the obligatory one month grace
before hitting the send button.
I shall not repeat myself too much here, but the issue is raised in the public domain now,
with the FBI, FCA and the PRA all investigating Jes Staley's conduct while working at JP Morgan,
which ostensibly should disqualify him from holding a sernior position in a bank - he was never fit
to be CEO of Barclays.
Clearly according the FOIA responses I received from the TSC, the blackmail emails from
Epstein should have been enough to have had Staley dismissed in 2015, and would give substantial
context to the emails held by JP Morgan. The TSC has had the Epstein emails now for almost five
years - and no MP and no civil servant did the honourable thing and demand the FCA investigate.
Mr Stride, do you take personal responsibility for the TSC witholding key legal evidence to
ongoing inquiries? Which civil servants in the TSC are involved with the cover-up? Are they
expecting a role in Barclays after the dust has settled?
Andrew Bailey of the FCA and Lisa Osofsky of the SFO both explicity refused to
investigate Staley after I supplied them with FOIA responses. Did the TSC order the FCA and the
SFO to stand down? It is only the US press that has forced the British establishment's hand. Had
Staley's role in JP Morgan not been reported there would be no investigation.
I believe the general public would be correct to infer that Epstein not only blackmailed
Parliament to put Staley into position, but blackmailed it into accepting Bailey and Osofsky. Both
would need to be corrupted in order for Staley to keep his job. Why is Bailey being considered for
top job at the Bank of England when the FCA that he runs has a 98% disapproval rating from the
general public.
Bailey and the FCA are answerable to the Treasury which is answerable to Parliament.
EFTA00019892

=== Page 2 ===
It is noted that Andrew Bailey and Mark Carney are being investigated for the LC&F
scandal.
To remind you, my friend
may well have been murdered for exposing the
Epstein and Staley story back in 2017. The timing of her death and the contents of her exposé were
given as evidence to Judge Worster of the Birmingham Court. The Court now refuses to accept my
emails and he stonewalls me. Worster served two restraining orders against me. The effect of these
orders is patent - they blocked the truth about Staley being publicly validated in a legal document
and signed off by a High Court judge. They also allowed Deutsche Bank to get away with never
having to file incriminating evidenec against themselves.
Did Worster take a bribe or was he ordered by the TSC to gag me? I presume if Staley was
going to bribe a judge to cover up his role in the Epstein paedophile circle, he would have to make
sure the Lord Chief Justice Ian Burnett was in the loop. Lord Etherton seems to have implied
Burnett was himself a paedphile. You may have heard about this. I wonder if Burnett was Epstein's
pick? Certainly someone who works with both Lord Adrian PIE Fulford and Paul Kernaghan has to
be highly suspect. I guess the truth must be in your email system somewhere.
Did you bother asking the FCA to investigate Roger Jenkins, who also appears to have also
gone to Epstein's child-rape parties?
Yours sincerely
Mark Anthony Taylor
EFTA00019893


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Proffer with witness
Date: Wed, 14 Aug 2019 21:01:52 +0000
Attachments: Epstein_Investigative_Reports.pdf
As discussed.
will join (who's the lead OIG agent) and we will join if we can. Can you send a calendar invite
to the three of us? Thank you.
From:
Sent: Wednesday, August 14, 2019 4:51 PM
To:
Cc:
Subject: Proffer with witness
How is tomorrow (Thursday) at 2:30pm?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00019347


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=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, S2 20 Cr. 330 (AJN) - Letter re S2 Indictment
Date: Mon, 29 Mar 2021 19:37:14 +0000
Attachments: 2021-03-29_Govt_Letter_to_GM_Counsel_re_S2_Indictment.pdf;
US_v_Maxwell,_S2_20_Cr_330_(AJN)_Indictment_(docketed).pdf
Counsel,
Please see the attached letter regarding the superseding indictment that was returned by a grand jury sitting in
Manhattan earlier today in the above-referenced case. Our team is available tomorrow between 1pm and 2pm, between
3pm and 5pm, or after 5:30pm to discuss the discovery issues you raised earlier, as well as whether supplemental briefing
on your pretrial motions would be appropriate in light of the new charges, and any other issues you would like to discuss.
Please let us know if you are available during those windows.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00019081


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=== Page 1 ===
From:
To:
Subject: FW: reporter query about Epstein
Date: Tue, 09 Jul 2019 18:54:29 +0000
Importance: Normal
FYI
From: Ostrowski, Jeffrey
Sent: Tuesday, July 09, 2019 14:26
To:
Subject: reporter query about Epstein
I'm writing about the indictment of Jeffrey Epstein, and I wonder if the government it plans to pursue the Palm
Beach property. I'm trying to reconcile the mention forfeiture of "any property" with the lack of a specific
mention of the address or legal description of the El Brillo Way real estate.
Thanks.
Jeff Ostrowski
Reporter
The Palm Beach Post Palm Beach Daily News GateHouse Florida
This message may contain confidential and/or privileged information. If you are not the intended recipient or authorized to
receive this for the intended recipient, you must not use, copy, disclose or take any action based on this message or any
information herein. If you have received this message in error, please advise the sender immediately by sending a reply e-
mail and delete this message. Thank you for your cooperation.
EFTA00018166


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=== Page 1 ===
From:
To:
Cc:
Subject: NYT; 'Uncontrollable' Jeffrey Epstein: 5 Takeaways From Judge's Bail Decision
Date: Fri, 19 Jul 2019 23:03:13 +0000
'Uncontrollable' Jeffrey Epstein: 5 Takeaways
From Judge's Bail Decision
By Ben Weiser
Mr. Epstein was willing to pay almost anything to stay out of jail. But the judge suggested he
could not curb his sexual fixation with minors.
July 19, 2019
f
[What you need to know to start the day: Get New
York Today in your inbox.]
A federal judge on Thursday denied Jeffrey
Epstein's request for bail pending his trial on sex-
trafficking charges in Manhattan. As a result, Mr.
Epstein, 66, a wealthy financier who owns a private
jet, luxury homes around the world and a private
island in the Caribbean, will have to spend months
in a Manhattan jail that typically holds accused
mobsters, drug dealers and terrorists.
The judge, Richard M. Berman of Federal District
Court, agreed with prosecutors that Mr. Epstein was
not only a flight risk, but posed a threat to others -
particularly teenage girls - if released.
The judge's strong rebuke of Mr. Epstein's conduct
and request to be allowed house arrest stood in
sharp contrast to how the authorities in Florida had
treated the financier in 2007.
EFTA00018384

=== Page 2 ===
That year, he reached a widely criticized deal that
let him avoid federal prosecution on charges he
sexually abused and trafficked minors. Instead, he
pleaded guilty to state charges of soliciting a minor
for prostitution and ended up serving 13 months in
jail. He was allowed to leave the facility six a days
a week, ostensibly to work.
Here are five takeaways from Judge Berman's
opinion.
Mr. Epstein was willing to pay almost any price
to stay out of jail
Unlike so many people charged in state and federal
courts, affording bail was not a problem for Mr.
Epstein. He had offered to post a gargantuan bond,
secured by his $56 million mansion on East 71st
Street in Manhattan and his private jet.
"I am authorized to say to the court," one of Mr.
Epstein's lawyers told Judge Berman, "that
whatever bond you want Mr. Epstein to sign -
whether it's $100 million or an amount close to the
amount of the assets that we have provided - Mr.
Epstein is prepared to sign it."
Mr. Epstein provided the court with a one-page
summary of his assets that placed their value as of
June 30 at $559 million.
His lawyers said he would even pay for 24-hour
private security to assure that he did not flee. The
government argued he was seeking special
treatment, a "gilded cage," as one prosecutor put it
in court.
EFTA00018385

=== Page 3 ===
The judge was concerned that if released, Mr.
Epstein would again abuse teenage girls
Judge Berman's decision portrayed Mr. Epstein as
sex offender who could not be trusted to curb his
sexual fixation with teenagers. He pointed to the
nature of Mr. Epstein's alleged crimes and his
propensity to commit them.
"The crimes Mr. Epstein has been charged with are
among the most heinous in the law principally, in
the court's view, because they involve minor girls,"
the judge wrote.
A federal indictment charged that between 2002 and
2005, Mr. Epstein and his employees paid dozens of
underage girls - at least one as young as 14 years
old - to give him massages while nude or topless
at his residences in Manhattan and Palm Beach,
Fla.
During the massages, he engaged in various sex
acts with them, the indictment said. He also used
some of the teenagers to recruit other girls to abuse,
paying the "victim-recruiters" hundreds of dollars
for each girl they brought to him, the indictment
said.
"Mr. Epstein's alleged excessive attraction to sexual
conduct with or in the presence of minor girls -
which is said to include his soliciting and receiving
massages from young girls and young women
perhaps as many as four times a day - appears
likely to be uncontrollable," Judge Berman wrote.
"It seems fair to say that Mr. Epstein's future
behavior will be consistent with past behavior," the
judge added.
EFTA00018386

=== Page 4 ===
His immense wealth, private planes,
international travel and liquid cash made Mr.
Epstein a flight risk
Given Mr. Epstein's wealth, the risk of flight was
"exceptionally high," the office of Geoffrey S.
Berman, the United States attorney in Manhattan,
told the judge in court papers.
Besides his New York mansion, Mr. Epstein's asset
summary listed multi-million-dollar properties in
New Mexico; Palm Beach; Paris and the Caribbean.
Prosecutors have said Mr. Epstein's primary
residence is a private island in the United States
Virgin Islands.
Mr. Epstein's assets also included $56 million in
cash and more than $300 million in securities and
other financial instruments. Prosecutors also said
his sex registration documentation (stemming from
his 2008 guilty plea in Florida) listed no fewer than
15 motor vehicles, including seven Chevrolet
Suburbans, a cargo van, a Range Rover, a
Mercedes-Benz sedan, a Cadillac Escalade and a
Hummer.
Then there was a safe that the authorities said they
searched in Mr. Epstein's mansion in Manhattan, in
which they found more than $70,000 in cash, 48
loose diamonds ranging in size from approximately
one to 2.38 carats, and a large diamond ring.
The judge concluded that Mr. Epstein was "a
serious risk of flight" and "no conditions can be set
that will reasonably assure his appearance at trial."
The contents of Mr. Epstein's safe gave the judge
pause
EFTA00018387

=== Page 5 ===
Inside that safe, the authorities also found an
Austrian passport bearing Mr. Epstein's photograph
but another person's name, the judge noted. The
judge's opinion made it clear that prosecutors and
Mr. Epstein's lawyers disagreed sharply over the
passport's significance.
Prosecutors said the passport showed Mr. Epstein
knew how to obtain false travel documents or
assume other identities.
Defense lawyers told the judge that Mr. Epstein,
whom they described as "an affluent member of the
Jewish faith, "acquired the passport in the 1980s
"when hijackings were prevalent," in connection
with Middle East travel. The passport expired 32
years ago, the defense wrote, and "was for personal
protection in the event of travel to dangerous areas,
only to be presented to potential kidnappers,
hijackers or terrorists should violent episodes
occur."
In the back and forth, prosecutors noted that the
passport included numerous stamps showing it was
used to enter France, Spain, Britain and Saudi
Arabia in the 1980s. The defense said Mr. Epstein
was given the passport by a friend, the trips were
not his and he had never used it.
The passport was not the only unusual item found
inside Mr. Epstein's mansion. The authorities said
they found hundreds and perhaps thousands of
sexually suggestive photographs of fully or partially
nude females, including photos that appeared to be
of underage girls. Some of the photos were
discovered in the locked safe.
The judge was concerned Mr. Epstein might try
to intimidate or buy off witnesses
EFTA00018388

=== Page 6 ===
Judge Berman also made it clear he thought Mr.
Epstein might seek to silence witnesses against him
if he were granted pretrial release. "Mr. Epstein's
dangerousness is considerable and includes sex
crimes with minor girls and tampering with
potential witnesses," the judge wrote.
The judge highlighted the government's argument
that Mr. Epstein had tried to influence possible
witnesses against him when he wired $350,000 late
last year to two people close to him, shortly after
the Miami Herald started publishing an exposé
about him. The Herald's series quoted his accusers,
described how he had sexually abused teens for
years, and laid out the lenient plea agreement he
had negotiated with the United States attorney in
Miami.
The judge also cited evidence from prosecutors that
Mr. Epstein or his representatives had harassed or
intimidated witnesses in civil suits.
For instance, he quoted a Palm Beach police report
in 2006 about a threat made to one of Mr. Epstein's
accusers. The report said the accuser had claimed
that one of Mr. Epstein's associates had told her that
those who helped Mr. Epstein "will be
compensated" and those who hurt him "will be
dealt with." In another case, a parent of one of Mr.
Epstein's alleged victims had reported that Mr.
Epstein's private investigator had driven the
parent's car off the road.
"A court may order detention if there is a serious
risk that the defendant will attempt to threaten,
injure or intimidate a prospective witness or juror,"
the judge noted.
EFTA00018389

=== Page 7 ===
Sent from my iPhone
EFTA00018390


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=== Page 1 ===
From:
To:
Subject: RE:
Review
Date: Tue, 30 Mar 2021 15:11:33 +0000
Attachments: USVP00222482_native.pdf
Saw the attached email, which I'm adding to this chain. Thanks.
From:
Sent: Friday, March 26, 2021 12:29 PM
To:
Subject:
Review
Hi - I came across this email and attachment while doing the review. I tagged it for further review, but wanted to
circulate.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00019602


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=== Page 1 ===
From:
To:
Subject: Post article on Epstein lawsuit
Date: Wed, 22 Jan 2020 17:35:08 +0000
https://nypost.com/2020/01/18/new-jeffrey-epstein-accuser-says-he-molested-her-at-13-told-her-to-wear-childrens-
underwear/
EFTA00018734


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=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
)"
(USANYS)"
)"
,
Christian Everdell
>, Jeff Pagliuca
, "Laura
Menninger"
Subject: US V. Maxwell - Proposed RTC and Verdict Sheet
Date: Thu, 04 Nov 2021 04:03:32 +0000
Attachments: 2021.11.03_Maxwell_verdict_sheet_[to_court].pdf;
2021.11.03_Maxwell_RTC_final_[unredacted].pdf; Exhibit_A.pdf; 2021-11-
03_RTC_and_Verdict_sheet_cover_letter.pdf:_202111.03_Maxwell_RTC_Junredacted].docx
Chambers,
Attached please find an unredacted request to charge, Exhibit A to the request to charge, and verdict sheet. The
Government will file a verdict sheet and redacted version of the request to charge on ECF. As set forth in the attached
letter, the Government seeks limited redactions on the request to charge, and the defense seeks sealing of Exhibit A.
Attached also is a Word version of the Request to Charge for the Court's convenience.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00018880


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=== Page 1 ===
June 7, 2021
prep
AUSA
SA
Det
Discussed schedule for trial prep, mechanics of trial testimony. USAO will pay for
to fly up to NY for trial, with her husband and children as support.
Since last meeting in January 2021,
received $3.5 million award from the Victim
Compensation Fund run by Epstein's estate. Several hundred thousand dollars of that
amount was taken out, and
ultimately received over $2 million.
used the money
to buy a new home for her family, a car, to pay off fines to get her license back, and to set
up an account for her children.
has had trouble sleeping over the past few months because she has dreams about
Epstein and is nervous about testifying at trial.
continues to speak with her counselor
every day and is prescribed medications to help with her mental health and addiction.
believes she lied to
about her age when they were dating. She
believes she told
that she was 17 years old when she was really younger. [NOTE:
was not feeling physically well during this interview, so no follow up questions were
asked about this topic during this meeting. AUSA arranged to meet with
later in the
week when
will hopefully be feeling better.]
EFTA00019915


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein/ Austria
Date: Mon, 22 Jul 2019 17:58:15 +0000
Importance: High
- Legat info below:
OIA also works closely with Alat
From:
(USANYS)
Sent: Monday, July 22, 2019 12:36 PM
To:
Cc:
Subject: RE: Epstein/ Austria
Hi
- do you have a few minutes to chat about it? I am free until 2 and again from 330-430, or most of tomorrow.
Thanks,
From:
Sent: Monday, July 22, 2019 12:28 PM
To:
Cc:
Subject: Epstein/ Austria
- The Austrian Embassy has just contacted me to ask whether they can be provided
information regarding the alleged Austrian passport that Epstein had in his possession. Is there
anything we can share in this regard? Thanks,
EFTA00020344


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=== Page 1 ===
From:
)"
To:
, Arraignment NYSD
Subject: FW: Signed warrant
Date: Thu, 09 Jul 2020 20:23:56 +0000
Attachments: Application for Second Warrant & Order (Maxwell_GPS).pdf; Exhibit A -
Maxwell signed indictment.pdf; Exhibit B - Maxwell arrest warrant_signed.pdf;
Exhibit C_-_2020.06.29_Application_for_Maxwell_GPS_Combo.pdf;_Exhibit_ -
2020.06.29_Maxwell_GPS_Combo_Warrant.pdf
Good afternoon,
Would someone be able to please send me a stamped copy of this application and warrant? Judge Parker sent the
attached signed copy late on June 30th, but I can't seem to find a stamped version with a mag number.
Thank you very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, June 30, 2020 10:10 PM
To:
)
Cc:
Subject: Signed warrant
Get Outlook for iOS
EFTA00020395


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=== Page 1 ===
From: "
)"
To:
)"
Subject: RE: epstein
Date: Wed, 10 Jul 2019 06:28:04 +0000
Importance: Normal
Sorry, this is belated (I had a draft sitting here since yesterday), but - correct, thanks.
From:
)
Sent: Monday, July 08, 2019 13:00
To:
)
Subject: RE: epstein
These things are no longer sealed, of course
From:
Sent: Monday, July 8, 2019 12:16 PM
To:
)
Subject: RE: epstein
Of course - attached.
From:
Sent: Monday, July 08, 2019 12:13
To:
Subject: epstein
Pls send me the indictment and the Detention Memo. Tx.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00018168


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
)"
Subject: New York search warrant materials
Date: Mon, 30 Sep 2019 17:56:40 +0000
Attachments: SW_Executed_7.11.19_report.pdf
The taint team here apparently received materials from the search of the New York house but it's way fewer documents
than we would have expected. Can you please let us know exactly how many electronic devices (phones, computers, hard
drives, thumb drives, and/or discs) were sent to CART for processing, and how many were in fact processed and sent back
to us? Or if it's easier to just put us in touch with the CART people directly, that's fine too. My understanding was that
they were processing the materials in the attached, which appears to list approximately 38 computers and/or electronic
storage devices seized along with an additional approximately 55 CDs.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00019728


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein victim call
Date: Wed, 17 Mar 2021 21:39:42 +0000
I was out last week and catching up this week. It was on my list of things to do today. I left her a voicemail to
call me back.
From:
Sent: Wednesday, March 17, 2021 2:22 PM
To:
is
is
Cc:
Subject: [EXTERNAL EMAIL] - RE: Epstein victim call
Hi
and
got a third call from this person. Could you please let us know the status of your outreach to her?
Thanks,
From:
Sent: Wednesday, March 10, 2021 4:15 PM
To:
is
Cc:
Subject: RE: Epstein victim call
Hi
and
checked in with us to tell us that this person called him again. Could you please let us know the status of your
outreach to her?
Thanks very much,
From:
Sent: Thursday, February 25, 2021 12:56 PM
To:
is
Cc:
is
Subject: FW: Epstein victim call
Hi
and
EFTA00019022

=== Page 2 ===
Please see below. Would someone at the FBI be able to contact this woman for initial screening, please? Per our usual
practice, if the screening suggests she may have useful information for our investigation, we can schedule an interview
with the team.
Thanks,
From:
Sent: Thursday, February 25, 2021 12:46 PM
To:
is
>;
Cc:
Subject: Epstein victim call
Team, I just received a call on my desk line from a woman named
who identified herself as a former
client of
and said she was a former victim of Jeffrey Epstein. I asked if her attorney had been in touch with
either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he had not
been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her cell phone as
She did not provide any substantive information on the call, and I did not ask for any. I advised that
someone would follow up with her, hopefully in the next week or so. The call lasted less than three minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine Epstein
victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing to speak
with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which we couldn't
find online). I believe the last communication we had with him was the attached.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00019023


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=== Page 1 ===
PROFFER AGREEMENT
With respect to the meeting of
("Client") and his/her attorney,
,
Esq., with Assistant United States Attorney
to be held at the Office of the
United States Attorney for the Southern District of New York on [Meeting Date] ("the meeting"),
the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to
provide the Government with information, and to respond to questions, so that the Government
may evaluate Client's information and responses in making prosecutive decisions. By receiving
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to enter
into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. The
Government makes no representation about the likelihood that any such agreement will be reached
in connection with this proffer.
(2) In any prosecution brought against Client by this Office, except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, any statements made by Client
at the meeting, except (a) in a prosecution for false statements, obstruction of justice or perjury
with respect to any acts committed or statements made during or after the meeting or testimony
given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive
from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information derived
directly or indirectly from the meeting for the purpose of obtaining leads to other evidence, which
evidence may be used in any prosecution of Client by the Government; (b) in any prosecution
brought against Client, the Government may use statements made by Client at the meeting and all
evidence obtained directly or indirectly therefrom for the purpose of cross-examination should
Client testify; and (c) the Government may also use statements made by Client at the meeting to
rebut any evidence or arguments offered by or on behalf of Client (including arguments made or
issues raised sua sponte by the District Court) at any stage of the criminal prosecution (including
bail, all phases of trial, and sentencing) in any prosecution brought against Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Section 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may
offer or use at any stage of the criminal proceeding any statement made by Client during the
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this Agreement to offer in evidence
any statements made by Client or leads obtained therefrom, Client shall assert no claim under the
United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or any other
federal rule that such statements or any leads therefrom should be suppressed. It is the intent of
this Agreement to waive all rights in the foregoing respects.
01.14.2019
EFTA00019831

=== Page 2 ===
(6) If this Office receives a request from another prosecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such information
but will do so only on the condition that the requesting office honor the provisions of this
Agreement.
(7) It is further understood that this Agreement is limited to the statements made by Client
at the meeting and does not apply to any oral, written or recorded statements made by Client at
any other time. No understandings, promises, agreements and/or conditions have been entered
into with respect to the meeting other than those set forth in this Agreement and none will be
entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 above extend to the continuation
of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully discussed and understand every
paragraph and clause in this Agreement and the consequences thereof.
Dated: New York, New York
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
by:
Client
Assistant United States Attorney
Attorney for Client
Witness
Dates of Continuation
Initials of counsel, Client, AUSA, witness
01.14.2019
EFTA00019832


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Cc:
(USANYS)"
Subject: RE: Filing today
Date: Thu, 13 Aug 2020 20:32:40 +0000
No, AJN's order just says our response is due today with no specific time.
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 4:30 PM
To:
i
Cc:
(USANYS)
Subject: FW: Filing today
This isn't due at 5, is it?
Original Message
From:
(USANYS) [Contractor]
Sent: Thursday, August 13, 2020 4:29 PM
To:
)
(USANYS)
(USANYS)
i
(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.)
Chief Public Information Officer
U.S. Attorney's Office, SDNY
(office)
(cell)
EFTA00020338


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=== Page 1 ===
From:
To:
Subject: [Not Virus Scanned] [WARNING: MESSAGE ENCRYPTEDJ[WARNING:
UNSCANNABLE EXTRACTION FAILEDJFW: Aircraft info
Date: Mon, 04 Oct 2021 20:11:45 +0000
Attachments: Registration_N722JE.pdf; Registration_N331JE_(Abbr).pdf; Hyperion_Air_LLC.pdf;
MG_Airman_File_(Encrypted).pdf; Dates_and_Locations_of_ME_(Encrypted).pdf
This message has not been virus scanned because it contains encrypted or otherwise protected data. Please
ensure you know who the message is coming from and that it is virus scanned by your desktop antivirus
software.
From:
(FAA)
Sent: Tuesday, January 14, 2020 11:26 AM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
Subject: RE: Aircraft info
Please call when you get this information.
I have attached Registration information for N331JE and N722JE. N722JE is the entire aircraft registration file. N331JE is
just the section that appeared to contain all relevant information to your case. I can give you the entire file if you think
there is more that might be applicable, and certified copies of the entire files can be obtained if they need to be used in
court. In my experience, sending the entire aircraft registration file from the start usually is daunting for the investigators,
and leads to tons of questions just trying to figure out what might be relevant. Sometimes aircraft files are 300 pages or
more, and that can be frustrating when maybe only 20 were relevant to the SUBJECT.
I have also attached the LLC Documents for Hyperion Air LLC which is the registered owner for both N331JE and N722JE.
I have attached the Airman File for the SUBJECT, which is encrypted due to PII. I will send the password in a follow-on e-
mail. I looked at the medical file, but I believe the information contained therein has limited value to your investigation. I
have created a separate encrypted document with only the information that may be helpful, so that you can evaluate
potentially relevant information while maintaining medical privacy. If the information in the airman file or the document I
created turns out to be critical evidence for your case, then certified copies of the airman and/or medical file can be
obtained at a later date.
As I mentioned previously, I want to clarify some details regarding the helicopters. What I found appeared to be slightly
different from what was included in the original e-mail to me below.
N722JE
nicknamed Air Ghislaine 2
Helicopter
Sikorsky S-76C
Aircraft Serial Number: 760750
Date Current Registration issued: 17 July 2019
Current Registered Owner: Hyperion Air LLC
EFTA00017875

=== Page 2 ===
Current Registration Signed By: Lawrence P. Visoski, Jr.
Aircraft Purchased from: ASI Wings LLC
Date of Purchase: 13 June 2019
Seller Signature: James D. Clark
Special Registration Number Issued on: Paperwork not properly submitted by requestor
Requested Special Registration Number: N162AE
Date Requested Special Registration Number: 16 September 2011 (one year authorization)
Bill of Sale: 18 July 2011
Aircraft Purchased by ASI Wings, LLC from: Freedom Air International, Inc
Aircraft Registered by: Freedom Air International, Inc
Registration of Aircraft on 02 August 2010 Signed By: Darren K. Indyke
Name Change To: Shmitka Air Inc
Name Change From: Air Ghislaine Inc
Date of Registered Owner Name Change: 11 February 2010
Requested Special Registration Number: N722JE
Special Registration Number Issued on: 10 March 2010
Date Requested Special Registration Number: 11 February 2010
Aircraft Registered by: Air Ghislaine, Inc.
Registration of Aircraft on 29 December 2008 Signed By: Larry Visoski
Aircraft Purchased from Sikorsky on: 30 December 2008
Aircraft Assigned Registration Number: N750A
N331JE
Helicopter
Bell 430
Aircraft Serial Number: 49078
Date Current Registration issued: 19 November 2019
Current Registered Owner: Hyperion Air, LLC
Current Registration Signed By: Lawrence Visoski
Aircraft Purchased from: Hyperion Air, Inc.
Date of Purchase: 12 August 2013
Seller Signature: Darren K. Indyke
Special Registration Number Placed on Aircraft: 25 June 2012
Requested Special Registration Number: N331JE
Special Registration Number Issued on: 04 June 2012
Date Requested Special Registration Number: 22 May 2012
Aircraft Purchased from: Bovale Developments, Inc.
Date of Purchase: 06 March 2012
Seller Signature: William P. Merriam Jr
Aircraft Registration Number: N901RL
EFTA00017876

=== Page 3 ===
N491GM
Helicopter
Bell 407
I have not yet been able to identify the serial number for N491GM which should lead to the registration documents. If you
know who the aircraft was sold to, or what registration number it currently uses, I would be able to obtain those
documents.
Finally, does this surname have any relevance to your case (potential pilot of one of the aircraft)? VAN HEURCK
V/r,
Law Enforcement Assistance Program (LEAP)
Federal Aviation Administration,
Office:
Cell:
From:
(NY) (FBI)
Sent: Friday, December 6, 2019 1:18 PM
To:
(FAA)
Cc:
;
(NY) (FBI)
Subject: Aircraft info
Hi
It was nice talking with you yesterday. Thanks for your assistance with this. Please see the below email of aircraft
information.
Below are the aircrafts we believe Maxwell has/had been using. The helicopter we know that she personally piloted, while
the jets we know her to be a passenger. You'll notice some of the aircrafts will be associated with Jeffrey Epstein, as she
traveled with him frequently. Any information you are able to provide would be helpful. If there is additional passenger
manifests for each of these aircrafts we'd like to know that as well. I know we discussed that sometimes that's not
available. As you can imagine, this case is high profile, so I appreciate any discretion you can make on your part.
Please let me know if I left something out that would be able to assist you in any way.
Thanks again,
Special Agent
FBI New York
Child Exploitation/Human Trafficking
C:
O:
From:
(NY) (FBI)
Sent: Friday, December 06, 2019 1:02 PM
To:
(NY) (FBI)
is
Subject: Aircraft info
Hello!
Below is the info for the helicopters and the private jet.
EFTA00017877

=== Page 4 ===
Name: Ghislaine Noelle Maxwell
Certificate: Private Pilot
Date of Issue: 10/2/2007
Helicopter: Rotorcraft
Sikorsky S-76C; nicknamed Air Ghislaine 2
Likely Serial Number: 760750
States certificate was issued on 7/17/2019
Helicopter Info:
Tail Number: N722JE
Type: 2008 Keystone Helicopter S-76C
Prior Registration: Freedom Air International Inc,
Wilmington, DE
Old Tail Number: N331JE
Serial Number: 49078
States certificate was issued on 9/6/2013
2nd Helicopter:
Bell Jet Ranger
Tail Number: N491GM
Nicknamed: Air Ghislaine 1
Private Jet:
Tail Number: N212JE
Serial Number: 5173
Type: GV SP (G550) Fixed Wing Multi Engine
Certificate Issued: 3/31/2017
Tail Number: N120JE
Serial Number: 1085
Type: G-IV Fixed Wing Multi Engine
Certificate Issued: 5/30/2013
Tail Number: N909JE
Serial Number: 151
Type: G1159B
Certificate Issued: 11/18/2013
Tail Number: N908JE
Serial Number: 20115
Type: Boeing 727-31
Certificate Issued: 1/25/2001
Let me know if you need anything else,
EFTA00017878


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=== Page 1 ===
From:
To:
Subject:
Review
Date: Fri, 26 Mar 2021 16:28:34 +0000
Attachments: USVP00157303.pdf; USVP00157304.pdf
Hi - I came across this email and attachment while doing the review. I tagged it for further review, but wanted to
circulate.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00019492


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=== Page 1 ===
MoneyGram International, Inc.
Attn: Global Subpoena Processing
1550 Utica Avenue South
MS: MBC-5508
Minneapolis, MN 55416
Delivered via: Email - subpoena@moneygram.com
The following are the items that are required to be provided by the attached Subpoena:
For the period of inception thru today, any and all available information regarding money transfers, the
purchase of money orders, including but not limited to, sender's name and address, location of purchase
including name and address of selling agent, form of payment used to purchase money orders, amount
of money orders purchased, date and time of purchase, the payee's name and address, the amount and
currency distributed.
Please utilize the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
If you have any questions or comments, please contact
Forensic Accountant, a
EFTA00020170


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 5, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
EFTA00018889

=== Page 2 ===
Page 2
Please note that this letter, the enclosed indices, and the enclosed materials are
governed by the July 31, 2020 Protective Order in this case. In particular, certain materials are
designated as "confidential" under the Protective Order. The index is itself designated as
"confidential," because it includes information regarding records designated as
"confidential" under the Protective Order. The Department of Justice directed this office to
cease the dissemination of materials marked with the word "confidential" in order to avoid
potential confusion with markings reserved for classified documents. Accordingly, in order to
note the appropriate designation of this production under the operative Protective Order in this
case, the materials being produced today are marked with the following label: "SUBJECT TO
PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to
the specific paragraphs of the Protective Order that govern today's production.
Additionally, please note that many of the individuals referenced in this production are
represented by counsel, as detailed in the enclosed indices. The Government reserves its right to
amend and supplement these disclosures.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
Assistant United States Attorneys
EFTA00018890


c1: EFTA00019782
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019782.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
mcc new YORK
MCC new TORN
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING WAIT
ZA
TIER-G
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1209
1210
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1241
1242
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
1"
(12)
9:00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
137
138
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
207
208
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
241
242
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
300
308
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
343
340
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
4"
47
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
440
4
12:30- 1:00 PM
8:30- 9:00 PM
5:00-5:30 AM
508
500
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
5"
542
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
410
u"
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019782

=== Page 2 ===
mcc new TORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIALHOUSING UNIT
SPECIAL HOUSING UNIT
ZA
TIER-H
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
12"
12
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1245
124
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
113
114
9:00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
1:37
139
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
2"
2
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
245
24
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
3"
3
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
343
344
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
414
4
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
+140
441
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
510
5"
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
543
5th
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
412
103
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates 1 onfined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at le: st once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another roun ! in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than .0 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019783

=== Page 3 ===
MCC new YORK
MCC NEW YORK
mcc new YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING WAIT
ZA
SPECIAL HOUSING WAIT
TIER-J
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1205
1206
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1239
1239
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
107
108,
9:00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
135
136
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
2,05
20
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2399
240
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
305
36
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
339
340
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
City
413
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
436
88/-
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
504
5°5
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
534
538
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
Cive
$9
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019784

=== Page 4 ===
mcc new YORK
MCC new TORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZA
SPECIAL HOUSING WAIT
TIER-K
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1207
1208
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1239
1040
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
109
110
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
137
138
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
267
208
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2"
242
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
307
308
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
341
342
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
4th
4
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
438
439
12:30- 1:00 PM
8:30-9:00 PM
5:00-5:30 AM
506
507
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
539
54
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
608
600
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019785

=== Page 5 ===
mcc new TORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIME HOUSING UNIT
ZA
TIER- L
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1201
12a
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1233
123
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
103
104
9:00-9:30 AM
5:00 -5:30 PM
1:30-2:00 AM
131
132
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
201
202
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
235
234
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
301
302
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
333
ICE
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
406
407
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
430
431
12:30- 1:00 PM
8:30- 9:00 PM
5:00-5:30 AM
500
50"
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
533
534
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
602
399
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019786

=== Page 6 ===
mcc new YORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING VAIT
ZA
TIER-M
DATE: 08/10/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1203
50
8:00-8:30 AM
4:00-4:30 PM
12:30- 1:00 AM
1235
123
8:30-9:00 AM
4:30-5:00 PM
1:00-1:30 AM
105
106
9:00-9:30 AM
5:00-5:30 PM
1:30-2:00 AM
133
134
9:30-10:00 AM
5:30-6:00 PM
2:00-2:30 AM
203
202
10:00-10:30 AM
6:00-6:30 PM
2:30-3:00 AM
2t
23
10:30-11:00 AM
6:30-7:00 PM
3:00-3:30 AM
303
3
11:00-11:30 AM
7:00-7:30 PM
3:30-4:00 AM
333
33
11:30-12:00 AM
7:30-8:00 PM
4:00-4:30 AM
408
400
12:00-12:30 PM
8:00-8:30 PM
4:30-5:00 AM
434
to
12:30-1:00 PM
8:30-9:00 PM
5:00-5:30 AM
502
50
1:00-1:30 PM
9:00-9:30 PM
5:30-6:00 AM
535
534
1:30-2:00 PM
9:30-10:00 PM
6:00-6:30 AM
604
605
2:00-2:30 PM
10:00-10:30 PM
6:30-7:00 AM
2:30-3:00 PM
10:30-11:00 PM
7:00-7:30 AM
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example, 12:30
am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be conducted
on an irregular schedule and no more than 40 minutes apart. All observations must be documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019787


c1: EFTA00019836
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019836.pdf
c6: pdf
c7: images
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=== Page 1 ===
Event: Accepted: Jason Mojica Proffer (Ordered) (re Epstein)
Start Date: 2019-09-10 16:30:00 +0000
End Date: 2019-09-10 17:30:00 +0000
Location: 500 Pearl Street - Q
Class: X-PERSONAL
Comment:
Date Created: 2019-12-13 05:58:19 +0000
Date Modified: 2019-12-13 05:58:19 +0000
Priority: 5
DTSTAMP: 2019-09-04 16:06:17 +0000
Attendee:
EFTA00019836


c1: EFTA00019444
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019444.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
JEGE, INC.
PASSENGER MANIFEST
Registration Number: N908JE
Type: B-727-31
Pilots:
Flight Engineer:
DATE: 120,200 2004 FROM PBI
TO
JFK
Departure
621 AM PM
Arrival
AM
8 39
Trip
Time
Time
PM
Number
243
PASSENGERS
1. Jeffrey Epstein
FROM Identifier Defined
2
City WEST PALM BEACH
3
State or Country
FL
TO Identifier Defined
City NEW YORK
6.
State or Country
N.Y.
7.
Nautical Miles
893
8.
Statute Miles
1027
9.
Gallons
AIRFRAME
10.
Pounds 19187 328539
11.
Flight Time 2.17
23
12.
Altitude FL F370 328562
13.
20.
Night
15
14.
21.
T/L
11
15.
22.
IMC
a
16.
23.
Approach
17.
24.
18.
25.
19.
26.
MM11-727 BOEING-N908JE_JEGE INC-000004
EFTA00019444


c1: EFTA00017872
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017872.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "LexisNexisDelivery@lexisnexis.com" <LexisNexisDelivery@lexisnexis.com>
To:
Subject: Updates for Track alert 'United States of America V. Maxwell'
Date: Wed, 27 Jan 2021 10:11:16 +0000
Attachments: United_States_of_America_v_Maxwell.PDF
LexisNe
Alerts
xis
New activity occurred in docket
United States of America V. Maxwell
Track Details
Information requested by:
Client ID: -None-
Monitor: Everything
Delivery: Wednesday
Description: No description available
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EFTA00017872


c1: EFTA00018900
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018900.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: RE: CNN - Epstein
Date: Fri, 16 Aug 2019 20:17:13 +0000
She said she would get back to me with the name of the AUSA
From:
Subject: Re: CNN - Epstein
It's hard to deny when they don't provide the name of the AUSA.
On Aug 16, 2019, at 4:11 PM,
wrote:
Hey guys,
CNN is pursuing a story about how
and
came to our Office in
2015/2016 to raise questions about the Epstein plea deal in Florida. Apparently through (with?) their attorney,
they talked to a sex trafficking or human trafficking AUSA (no name yet) about the issue. The reporter believes
that it was not raised to senior leadership at the time and it went nowhere.
CNN doesn't plan to run something immediately but knows that another reporter has similar information,
so if they feel their competition will go with the story, they will, too.
Any guidance or thoughts are welcome.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Email:
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00018900


c1: EFTA00018572
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018572.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6
CG
COHEN & GRESSER LLP
New York, NY 10022
+1 212 7600 phone
www.cohengresser.com
Mark S. Cohen
Christian R. Everdell
August 10, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
New York, New York 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion
seeking the Court's assistance with two critical issues that greatly impact Ms. Maxwell's ability
to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an
order directing the government to disclose to defense counsel the identities of the three alleged
victims referenced in the indictment ("Victims 1-3"), subject to the restrictions of the protective
order entered by the Court, so that Ms. Maxwell and defense counsel can meaningfully
investigate the alleged conduct, which is now over 25 years old. Second, we request that the
Court enter an order directing the Bureau of Prisons ("BOP") to release Ms. Maxwell into the
general population and provide Ms. Maxwell with increased access to the discovery materials
while she is detained so that she can meaningfully participate in the preparation of her defense.
1.
Disclosure of Victim Identities
The Court should order the government to disclose the identities of Victims 1-3 to
defense counsel, subject to the restrictions of the protective order, because Ms. Maxwell cannot
prepare for or receive a fair trial without this information. Moreover, the requested disclosure is
authorized under the law in this Circuit, and is narrowly-tailored and reasonable under the
circumstances of this case.
Here, it is clear from the face of the indictment that the government's case is based on the
accounts of Victims 1-3, the three individuals specifically referenced in the indictment. It is
therefore critical for the defense to know the names of these individuals as soon as possible, so
EFTA00018572

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Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 2 of 6
The Honorable Alison J. Nathan
August 10, 2020
Page 2
that we can mount an effective defense investigation and adequately prepare for trial. This is
especially true in this case where the alleged misconduct took place on unspecified dates roughly
25 years ago in multiple locations-namely, New York, Florida, New Mexico, and the United
Kingdom-and where the central figure, Jeffrey Epstein, is alleged to have engaged in
misconduct with dozens, if not hundreds, of alleged victims. The defense should not have to
speculate which of these individuals are Victims 1-3 referenced in the indictment.
It is now almost six weeks since Ms. Maxwell's arrest, and the government is just now
beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would
begin as soon as the Court entered a protective order. Moreover, the government still has not
confirmed to the defense the identities of Victims 1-3. Ms. Maxwell was arrested on July 2,
2020. On July 14, 2020, during her arraignment and bail hearing, the government indicated that
it had "begun preparing an initial production" and would be "prepared to produce a first batch of
discovery as soon as a protective order [was] entered by the Court." The Court entered the
protective order on July 30, 2020. (Dkt. 36). The following day, July 31, 2020, defense counsel
contacted the government and requested disclosure of the identities of Victims 1-3. The
government refused to do so, stating that it would only disclose the identities of alleged victims
through its production of Rule 16 discovery, or as part of its production of Jencks Act material
closer to trial. That same day, per the government's request, the defense provided a hard drive to
load the Rule 16 discovery. However, the government did not make its first production until
after 2:00 p.m. on Wednesday, August 5, 2020.
The government's initial production was a subset of non-electronic discovery materials,
totaling nearly 13,000 pages, which the defense expeditiously reviewed for high-level content.
Upon initial review, the materials contain certain records related to one specific individual.
However, nothing in the production specifically identifies this individual as Victim 1, 2, or 3.
The defense should not be required to speculate whether this individual is one of the three
alleged Victims, and if so, which one. Moreover, the initial production does not appear to
contain any materials identifying the other two alleged Victims. Although the government has
indicated that it will provide additional discovery on a rolling basis, if the initial production is
any guide, it seems unlikely that later productions will sufficiently identify the remaining alleged
Victims. Furthermore, the defense should not be forced to wait almost two additional weeks
until August 21, 2020 (the deadline for the production of initial non-electronic discovery) or
potentially months until November 9, 2020 (deadline for the completion of all discovery) before
learning information that is vital to the defense. Ms. Maxwell's right to a fair trial depends on
the defense's ability to adequately investigate the charges against her, and that investigation will
be significantly impaired until we know for certain the names of Victims 1-3.
I
July 14, 2020 Tr. at 12:14-17; see also id. at 12:25-13:3 ("Following the entry of [the] protective order
the
government is prepared to make a substantial production of discovery.").
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The Honorable Alison J. Nathan
August 10, 2020
Page 3
District courts have the inherent authority to compel pretrial disclosure of the identities of
government witnesses. See United States V. Cannone, 528 F.2d 296, 301 (2d Cir. 1975). Such
disclosure is warranted when there is a specific showing that the disclosure is material to the
preparation of the defense and reasonable in light of the circumstances surrounding the case. See
id. at 302; United States V. Rueb, No. 00 CR. 91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb.
5, 2001) (ordering disclosure of government witness list where defendant "ha[d] met his burden
to show a particularized need that outweighs the possible dangers of disclosure"). 2 This
principle has been applied in sex crimes cases, where the right of the defendant to prepare a
defense can outweigh the privacy interests of alleged victims referenced in the indictment and
warrant the disclosure of their identities. See United States V. Warme, No. 09CR19A, 2009 WL
427111, at *2 (W.D.N.Y. Feb. 20, 2009) (ordering government to disclose identity of sex crime
victim where "defendant's ability to adequately prepare a defense against this charge is
significantly compromised without being advised of the identity of the alleged victim"); see also
id. ("Absent knowing the identity of Victim 1, the defendant is precluded from investigating the
facts surrounding the crime charged.").
The defense's narrowly-tailored request, which only seeks the disclosure of the identity
of Victims 1-3, and not the government's entire witness list, is also reasonable in light of the
circumstances of this case. And because the protective order prohibits Ms. Maxwell, defense
counsel, and others on the defense team from disclosing or disseminating the identity of any
alleged victim or potential witness referenced in the discovery materials (Dkt. 36 1 5), the
disclosure will have no impact on the privacy interests of Victims 1-3. Nor is there any basis for
the government to claim that there is a risk that witnesses will face intimidation or refuse to
testify. 3 To the contrary, many alleged victims have already chosen to speak on the record in
criminal proceedings in the Epstein case and in this case; to file civil suits against Mr. Epstein,
Ms. Maxwell and others, and to provide deposition testimony and discovery in those suits; and to
give interviews to the press and other television and film productions. Moreover, Victims 1-3
are no longer minors, but are now adults in their late 30s or early 40s, which provides additional
assurance that they will be willing to appear for trial. Disclosure is therefore warranted here.
2 In determining whether to order pretrial disclosure of the identity of witnesses, some district courts have
considered the following factors: (1) Did the offense alleged in the indictment involve a crime of violence? (2)
Have the defendants been arrested or convicted for crimes involving violence? (3) Will the evidence in the case
largely consist of testimony relating to documents (which by their nature are not easily altered)? (4) Is there a
realistic possibility that supplying the witnesses' names prior to trial will increase the likelihood that the
prosecution's witnesses will not appear at trial, or will be unwilling to testify at trial? (5) Does the indictment allege
offenses occurring over an extended period of time, making preparation of the defendants' defense complex and
difficult? (6) Do the defendants have limited funds with which to investigate and prepare their defense? Rueb,
2001 WL 96177, at *7-8 (citation omitted). The Second Circuit, however, has not adopted these factors, nor do they
constitute an exhaustive list of factors that the Court may consider in determining whether to disclose the identities
of alleged victims.
3 Notably, the government did not argue at the bail hearing that Ms. Maxwell posed a danger to the community.
(See 7/14/2020 Tr. at 37:15-21).
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The Honorable Alison J. Nathan
August 10, 2020
Page 4
See Warme, 2009 WL 427111, at *2 (ordering government to disclose identity of sex crime
victim where "the government has not demonstrated that disclosing the identity to the defendant
would subject the victim to a significant risk, or to increase the likelihood that victim will refuse
to appear or testify").
With each day that passes without knowing the identities of Victims 1-3, the defense is
losing crucial time to conduct a meaningful investigation and prepare its defense so that Ms.
Maxwell can receive a fair trial on the schedule set by the Court. For these reasons, we
respectfully request the Court to order the government to disclose the identities of Victims 1-3 to
defense counsel, consistent with the provisions of the protective order.
2. Ms. Maxwell's Conditions of Confinement and Access to Discovery
We also seek the Court's assistance to improve Ms. Maxwell's conditions of confinement
at the Metropolitan Detention Center ("MDC"), and her access to the discovery in this case, so
that she can meaningfully participate in her defense. As discussed below, Ms. Maxwell has been
treated less favorably than a typical pretrial detainee, and this has impacted her ability to assist in
her defense.
It has become apparent that the BOP's treatment of Ms. Maxwell is a reaction to the
circumstances surrounding the pretrial detention and death of Mr. Epstein. On July 6, 2019, Mr.
Epstein was arrested and detained at the Metropolitan Correctional Center ("MCC") on sex
trafficking charges, and was subsequently assigned to the MCC's Special Housing Unit ("SHU")
due to risk factors for suicide and safety concerns. After an apparent suicide attempt on July 23,
2019, Mr. Epstein was transferred to suicide watch and then psychological observation. On
August 10, 2019, Mr. Epstein's body was discovered in his cell. Thereafter, the government
indicted the two correctional officers who were assigned to the SHU at the time of Mr. Epstein's
death.
As a result of what occurred with Mr. Epstein, Ms. Maxwell is being treated worse than
other similarly situated pretrial detainees, which significantly impacts her ability to prepare a
defense and be ready for trial on the schedule set by the Court. Since arriving at the MDC over a
month ago, on July 6, 2020, Ms. Maxwell has been held under uniquely onerous conditions. Ms.
Maxwell has been confined alone in an area outside of the general population for the entire 36-
day period (40 days if we include her confinement in New Hampshire), which is over three
weeks longer than the 14-day quarantine period required for all new arrivals to the MDC under
current COVID-19 protocols, and there is no indication that this will change. She continues to
be surveilled 24 hours a day by security cameras and by multiple prison guards, many of whom
do not appear to be regular MDC personnel. These prison guards constantly observe Ms.
Maxwell and take notes on her every activity, including her phone conversations with defense
counsel. Until recently, Ms. Maxwell was subjected to suicide watch protocols, including being
woken up every few hours during the night and being forced to wear special clothing, despite the
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=== Page 5 ===
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 5 of 6
The Honorable Alison J. Nathan
August 10, 2020
Page 5
fact that she, unlike Mr. Epstein, has never been suicidal and was never diagnosed as exhibiting
risk factors for suicide. Her cell is searched multiple times a day and she has been forced to
undergo numerous body scans. In addition, Ms. Maxwell's access to the standard prison
resources available to other pretrial detainees in the general population has been extensively
curtailed or eliminated altogether.
This treatment threatens Ms. Maxwell's Sixth Amendment right to participate in her
defense. This case will require time-consuming review of voluminous discovery materials. Ms.
Maxwell must therefore have adequate time to review the materials, to confidentially take notes
on them, and to discuss them with her attorneys. But there currently is no such structure in
place. Indeed, although the government agreed that Ms. Maxwell would have access to a hard
drive containing the discovery in the MDC, it is our understanding that the hard drive containing
the first production has not yet been made available to Ms. Maxwell.
Defense counsel understands that the BOP has proposed (but not yet implemented) a
procedure that would permit Ms. Maxwell to use a computer on her floor to review discovery
materials during the three-hour period each day that she is not confined to her cell. But there are
two significant flaws in this proposal:
The three-hour period is specifically designated to be used by Ms.
Maxwell for recreation, exercise, and personal hygiene, including
showers. The BOP should not be permitted to force Ms. Maxwell to
choose between maintenance of her physical and mental health and
participating in her own defense.
Even if Ms. Maxwell were to forgo personal maintenance altogether, three
hours a day is on its face an insufficient amount of time for reviewing
documents in a complex case with voluminous document discovery, such
as this one. As an illustration, the government's first set of production
materials consists of nearly 13,000 pages of documents. Assuming it
takes Ms. Maxwell an average of one minute to review each page of those
materials, based on the BOP's proposed cap of three hours per day of
review, Ms. Maxwell would conceivably finish reviewing this first set of
documents at the earliest by mid-November 2020. This is entirely
unworkable under the schedule set by the Court.
Ms. Maxwell does not seek special treatment at the MDC; but she does ask that she not
be specially disfavored in her treatment in detention, especially when it comes to preparing her
defense to conduct that allegedly took place over 25 years ago. In light of the voluminous
discovery that we expect to receive, Ms. Maxwell would normally be spending 40 hours a week
or more reviewing the discovery. Ms. Maxwell should be granted a comparable amount of time
EFTA00018576

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 6 of 6
The Honorable Alison J. Nathan
August 10, 2020
Page 6
to review the discovery in the MDC so that she can engage in her defense full-time. We
therefore request that Ms. Maxwell:
Be released to the general population and be granted the privileges given
to other pretrial detainees.
Be given significantly increased access to a computer terminal in order to
review the discovery in this case.
*
*
*
For the reasons set forth above, we respectfully submit that the Court should grant Ms.
Maxwell's motion.
Respectfully submitted,
/s/ Christian R. Everdell
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
New York, New York 10022
cc: All counsel of record (via ECF)
EFTA00018577


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c7: images
c0:
=== Page 1 ===
Event: Meeting re MCC/Epstein
Start Date: 2019-08-13 15:45:00 +0000
End Date: 2019-08-13 16:15:00 +0000
Organizer:
(USANYS)
Location:
$ office
Class: X-PERSONAL
Date Created: 2019-08-13 12:17:35 +0000
Date Modified: 2019-08-13 12:17:35 +0000
Priority: 5
DTSTAMP: 2019-08-13 12:05:14 +0000
Attendee:
(USANYS)
i
(USANYS)
>;
(USANYS)
EFTA00019332


c1: EFTA00018113
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018113.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: Mark Steward <Mark.Steward@fca.org.uk>
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>,
(USANYS)"
Keny Endred
<Kelly.Eldred@fca.org.uk>, Harry Caldecott <Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Date: Thu, 28 Nov 2019 18:09:31 +0000
Of course - thank you very much for reaching out, we appreciate it. Will be in touch next week.
Best,
Sent from my iPhone
On Nov 28, 2019, at 12:59 PM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Thanks for taking the call today and look forward to speaking again early next week. And happy
Thanksgiving !
Kind regards
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:57
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
To allow a few of my colleagues to join, can we instead use a dial in:
EFTA00018113

=== Page 2 ===
Thanks, and talk soon
Sent from my iPhone
On Nov 28, 2019, at 10:31 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Great much appreciated thanks
From
Sent: 28 November 2019 15:30
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <<Mark.Steward@fca.org.uk>;
is
;
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Okay, please call my cell:
Sent from my iPhone
On Nov 28, 2019, at 10:25 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Hi Ted,
I have spoken to Mark's business support and he is available at 4.15pm (UK time) today (ie in just
under an hour's time). It is quite urgent so if we could speak then it would be greatly appreciated.
If that does work please let us know what number to call you on?
Many thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 14:53
To: Mark Steward <Mark.Steward@fca.org.uk>
Cc:
;
(USANYS)
i
Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Hi Mark - Thanks for reaching out. We do have an active investigation and would be happy to talk. As you likely
know, today is a holiday in the US. Is this something we could discuss on Monday or is it more urgent than that?
Thanks,
Sent from my iPhone
On Nov 28, 2019, at 9:28 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
EFTA00018114

=== Page 3 ===
Dear
Can I ask whether this is still an active matter ? if so, I wonder if we could
speak when it is convenient.
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
Sent: 28 November 2019 14:25
To: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
is
(USANYS)
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Looping in
. They run our
unit and oversee the Epstein case.
Sent from my iPhone
On Nov 28, 2019, at 8:30 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Hi
Can you let me know, urgently, whether anyone in your office is handling the investigation into
Jeffery Epstein, especially anything in relation to JP Morgan (he was a client of their private wealth
division) and, if so, who, as we need to have a chat. If this is not in SDNY, do you know who is
handling ongoing work into Mr E's world ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
EFTA00018115

=== Page 4 ===
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received
this email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer.
Further information on the classification and handling of FCA information can be found on the FCA website
(http://www.fca.org.uk/site-info/legal/fca-clasified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received
this email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer.
Further information on the classification and handling of FCA information can be found on the FCA website
http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
EFTA00018116

=== Page 5 ===
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received this
email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further
information on the classification and handling of FCA information can be found on the FCA website
(http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA
Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-
privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
EFTA00018117

=== Page 6 ===
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on
the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor
all email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships.
This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No.
8970864. Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
EFTA00018118


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=== Page 1 ===
From:
To:
)"
)"
Subject: FW: Contact Info Daniel Siad (from Brunel)
Date: Thu, 06 Dec 2018 18:40:33 +0000
Importance: Normal
Attachments: 20160502_193023_resized.jpg
FYI
From: StanPottinger
Sent: Tuesday, May 3, 2016 12:02 PM
To:
Cc:
Subject: Fwd: Contact Info Daniel Siad (from Brunel)
Yesterday I spoke of Daniel Siad, whom Jean Luc Brunel describes as a "scout" or recruiter of girls and/or women for J.
Epstein. Attached to this incoming email from Brunel is the contact information he has for Siad.
Best regards,
Stan
From:
To:
Sent: 5/3/2016 11:13:15 A.M. Eastern Daylight Time
Subj: (no subject)
Sent from my Samsung Galaxy smartphone.
EFTA00017956


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 01:55:24 +0000
Thanks,
From:
Sent: Sunday, November 28, 2021 10:29 AM
To:
-
>; Drescher, Sunny
Subject: FW: United States V. Ghislaine Maxwell --
opens
Good Luck, Guys! Go Get 'Em,
From:
Sent: Sunday, November 28, 2021 9:59 AM
To:
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019216


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=== Page 1 ===
1
UNITED STATES DISTRICT COURT
2
SOUTHERN DISTRICT OF NEW YORK
3
4
JANE DOE,
Case No.
5
Plaintiff,
COMPLAINT FOR DAMAGES
6
V.
7
DARREN K. INDYKE and RICHARD D.
8
KAHN, in their capacities as executors of the
DEMAND FOR JURY TRIAL
ESTATE OF JEFFREY E. EPSTEIN,
9
GHISLAINE MAXWELL, an individual,
10
Defendants.
11
fax
12
Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges as follows:
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699
13
INTRODUCTION
14
1.
This case arises out of years of sexual abuse and exploitation of a young girl by
15
notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994
16
when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a
17
summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused
18
by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and
19
psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her
20
story, to hold her perpetrators accountable and to seek justice for the atrocities committed against
21
her.
22
2.
Throughout his life, Epstein systematically perpetrated acts of molestation,
23
exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was
24
facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him
25
with a steady stream of young and vulnerable girls-many of whom were fatherless, like Jane
26
Doe, and came from struggling families.
27
28
1
COMPLAINT FOR DAMAGES
EFTA00019101

=== Page 2 ===
1
3.
This system, which took years to develop, all started with them exploiting and
2
abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their
3
network of additional sexual abuse victims.
4
THE PARTIES
5
4.
Plaintiff Jane Doe is a citizen of the State of California. At all times relevant to this
6
suit, Doe was a minor child living in Florida and New York and who was sexually abused while
7
she was a minor by Defendants in New York.
8
5.
Defendant Ghislaine Maxwell is domiciled in the State of New York.
9
6.
Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the
10
Estate of Jeffrey E. Epstein.
11
7.
Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the
fax
12
Estate of Jeffrey E. Epstein.
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699
13
JURISDICTION AND VENUE
14
8.
Plaintiff is domiciled in California.
15
9.
Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin
16
Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein,
17
Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands. The matter
18
in controversy exceeds the sum of $75,000, and therefore jurisdiction in this Court is proper. 28
19
U.S.C. $ 1332(c)(2).
20
10. Ghislaine Maxwell is domiciled in New York.
21
11. A substantial part of the events giving rise to these causes of action occurred in the
22
Southern District of New York, thus venue in this district is proper. 28 U.S.C. § 1391(b)(2).
23
JURY DEMAND
24
12. Plaintiff hereby demands a trial by jury on all of her claims in this action.
25
FACTUAL ALLEGATIONS
26
Epstein and Maxwell's Abuse of Doe
27
13.
In the summer of 1994, Jane Doe met Jeffrey Epstein and Ghislaine Maxwell at
28
Interlochen Arts Camp in Michigan when she was only 13-years-old. Doe was there as a student
2
COMPLAINT FOR DAMAGES
EFTA00019102

=== Page 3 ===
1
in the voice program. Doe was sitting alone on a bench between classes when Epstein and
2
Maxwell approached her. Epstein bragged to her about being a patron of the arts and giving
3
scholarships to talented young artists like Doe. Epstein and Maxwell probed her at length about
4
her background, family situation and where she lived. As Doe got up to leave, Epstein requested
5
her mother's phone number back in Florida. She was alarmed by his request, but also feared that
6
she could not refuse the older man's request so she complied and provided him with the phone
7
number.
8
14. Several weeks later, once Doe had returned from Michigan to Florida, Epstein
9
called Doe's home. Epstein first spoke with Doe's mother about how he mentors young kids and
10
provides scholarships for the arts. He requested to speak to Doe and invited her and her mother to
11
his mansion in Palm Beach. He sent a driver across town to pick them up.
12
15. Over the course of the next several months, Epstein and Maxwell attempted to
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699 fax
13
groom and mentor 13-year-old Jan Doe. Epstein gave himself the name of Doe's "godfather"
14
while Maxwell acted like an older sister to her. They took her to movies, went shopping with her
15
and lounged around Epstein's estate with her. Epstein and Maxwell then started to make sexual
16
references when they were with her. For instance, Maxwell told Doe that having sex with ex-
17
boyfriends was easy because once you slept with them "they' been grandfathered in and you
18
could go back and fuck them whenever you wanted." Epstein also started to slowly display his
19
pedophilic ways when shopping with Doe and Maxwell. Instead of Doe picking out clothes she
20
wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear.
21
Also, after nearly every visit with Epstein and Maxwell, Epstein sent Doe home with two or three
22
one-hundred-dollar bills to give her mother since "she's having a hard time and struggling as a
23
widow."
24
16. While these visits made Doe extremely uncomfortable, Epstein and Maxwell made
25
her feel she could not refuse them. During this time, Epstein started to pay for voice lessons for
26
Doe and insisted that Doe could not advance her career in any way without him. When Doe
27
expressed hesitation about spending time with Epstein and Maxwell or acquiescing to their
28
desires, Epstein and Maxwell would threaten Doe, and scold her for being "ungrateful".
3
COMPLAINT FOR DAMAGES
EFTA00019103

=== Page 4 ===
1
17. During one of Doe's encounters with Epstein, he took her to Mar-a-Lago where he
2
introduced her to its owner, Donald J. Trump. Introducing 14-year-old Doe to Donald J. Trump,
3
Epstein elbowed Trump playfully asking him, referring to Doe, "This is a good one, right?"
4
Trump smiled and nodded in agreement. They both chuckled and Doe felt uncomfortable, but, at
5
the time, was too young to understand why.
6
18. Towards the end of 1994, Epstein invited Doe into his pool house, where he
7
grabbed her, put her on his lap and started masturbating. Epstein told her that was what to expect
8
from photographers who were soon going to be take modeling pictures of her. However, when
9
Doe was ultimately photographed by these professional photographers, they did no such thing.
10
19. Over the next few years, the sexual abuse escalated. On a regular basis, Epstein
11
would digitally penetrate Doe, force Doe to perform sexual acts on him and apply vibrators on
12
different parts of Doe's body. The abuse occurred at Epstein's home in Palm Beach, Florida,
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699 fax
13
Epstein's townhouse on 9 East 71st Street in New York City, and Epstein's ranch in New Mexico.
14
When travelling to these places, Doe often flew with Epstein and Maxwell in Epstein's private jet.
15
20. In 1996, when Doe was 16-years-old, Epstein moved Doe to New York City. At
16
first, Epstein put Doe up in his apartment on 65th Street and 2nd Avenue. After a few months,
17
Epstein co-signed the lease for Doe and Doe's mother for an apartment. Additionally, Epstein paid
18
her tuition at a private high school in Manhattan as well.
19
21. Once Epstein had secured Doe in New York and made her and her family
20
completely dependent on him financially (including, for the roof over their heads), Epstein's abuse
21
of Doe continued to escalate.
22
22. In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New
23
York, Epstein asked 17-year-old Doe if she had a boyfriend. Doe replied that she did not. Epstein
24
responded that when she did have a boyfriend she would want the sex to be "good" and that she
25
should "get it over with already," meaning lose her virginity. Despite Doe's resistance, Epstein
26
then pushed Doe down onto her stomach and raped her. From that point forward for several years
27
in New York, Epstein raped Doe on multiple occasions.
28
4
COMPLAINT FOR DAMAGES
EFTA00019104

=== Page 5 ===
1
23. During Doe's time in New York, Maxwell also regularly facilitated Epstein's abuse
2
of Doe and was frequently present when it occurred.
3
24. In 1999, Doe moved to Los Angeles to start a career. Upon moving to Los Angeles
4
and being physically away from Epstein and Maxwell, Doe finally felt like she could escape
5
Epstein's abuse and stopped returning his frequent calls where he would threaten and berate her for
6
not appreciating him.
7
25. Despite Doe's physical escape from Epstein and Maxwell, the years of abuse and
8
exploitation perpetrated against her by them cause her immeasurable pain and suffering every day.
9
Epstein's Death and Will
10
26. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the
11
Southern District of New York.
fax
12
27. On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699
13
Correctional Center, where he was being held pending trial. Upon information and belief, New
14
York City's medical examiner concluded Epstein died by suicide.
15
28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the
16
Probate Division of the Superior Court of the Virgin Islands.
17
29. The Will indicated that it was executed by Epstein on August 8, 2019 at the
18
Metropolitan Correctional Center. The Will was accompanied by affidavits from Darren K.
19
Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and
20
Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for
21
Letters Testamentary in the Superior Court of the Virgin Islands.
22
30. The Will's first article directs Epstein's executors "to pay from my estate all
23
expenses of my last illness, my funeral and burial expenses, the administration expenses of my
24
estate and all of my debts duly proven and allowed against my estate." The Will further directs
25
that "after the payments and distributions provided in Article FIRST," Epstein "give[s] all of my
26
property, real and personal, wherever situated to the then acting Trustees of The 1953 Trust."
27
28
5
COMPLAINT FOR DAMAGES
EFTA00019105

=== Page 6 ===
1
31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with
2
the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are
3
the two Trustees of The 1953 Trust.
4
32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the
5
Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and
6
authorized Mr. Indyke and Mr. Kahn to administer the estate.
7
FIRST CAUSE OF ACTION
8
(Sexual Assault)
9
33. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
10
if set forth fully herein.
11
34. On numerous occasions over several years, Epstein, with Maxwell's assistance,
fax
12
made violent sexual demands on Plaintiff while placing his hands on her body in a position of
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699
13
dominance and control and while touching Plaintiff in violent and invasive ways.
14
35. These demands, often made when young Plaintiff was alone with Epstein or with
15
only Epstein and Maxwell, were intended to frighten Plaintiff into submitting to his sexual
16
demands and placed Plaintiff in apprehension of harm.
17
36. This conduct caused Plaintiff serious and persistent harm and contributed to
18
injuries that Plaintiff continues to suffer.
19
37. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
20
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
21
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
22
the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. $ 130.55.
23
SECOND CAUSE OF ACTION
24
(Sexual Battery)
25
38. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
26
if set forth fully herein.
27
39. On numerous occasions over several years, Epstein raped Doe.
28
6
COMPLAINT FOR DAMAGES
EFTA00019106

=== Page 7 ===
1
40. On numerous occasions over several years, Epstein digitally penetrated Doe with
2
his fingers, tongue and foreign objects.
3
41. On numerous occasions over several years, Epstein made otherwise unwanted,
4
unlawful, harmful, and offensive physical contact with Plaintiff's body.
5
42. This conduct caused Plaintiff serious and persistent harm and contributed to
6
injuries that Plaintiff continues to suffer.
7
43. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. $ 214-g
8
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
9
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
10
the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. $ 130.55.
11
THIRD CAUSE OF ACTION
fax
12
(Intentional Infliction of Emotional Distress)
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699
13
44. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
14
if set forth fully herein.
15
45. Epstein and Maxwell's campaign of sexual abuse against a teenaged Plaintiff was
16
extreme and outrageous conduct that shocks the conscience.
17
46. Epstein and Maxwell's serial sexual assaults, committed during the course of a
18
methodical plan of recruitment, enticement, and attack, inflicted severe pain and anguish upon
19
Plaintiff.
20
47. Epstein and Maxwell directed this conduct at Plaintiff and knew that it would cause
21
severe and lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting
22
emotional distress and serious injuries to her mental health.
23
48. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
24
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
25
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
26
the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
27
FOURTH CAUSE OF ACTION
28
(Negligent Infliction of Emotional Distress)
7
COMPLAINT FOR DAMAGES
EFTA00019107

=== Page 8 ===
1
49. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
2
if set forth fully herein.
3
50. Epstein and Maxwell coaxed Plaintiff, then a teenaged girl, into Epstein's home for
4
a period of several years. They worked hard to groom her. Once under their supervision and
5
influence, Epstein and Maxwell proceeded methodically to sexually abuse Plaintiff.
6
51. Epstein and Maxwell's conduct was extreme and outrageous, breached a duty owed
7
directly to Plaintiff, endangered her physical safety, and caused severe and lasting emotional
8
distress and serious injuries to Plaintiff's mental health.
9
52. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. $ 214-g
10
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
11
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
12
the New York Penal Law ("Article 130"). See N.Y. P.L. $ 130.52; N.Y. P.L. $ 130.55.
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699 fax
13
FIFTH CAUSE OF ACTION
14
(False Imprisonment)
15
53.
Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
16
if set forth fully herein.
17
54. Defendants, in perpetrating the above-described non-consensual sexual assaults,
18
did, by use of threat and/or physical force, willfully and intentionally confine, detain, imprison
19
and/or restrain Plaintiff without lawful authority to do so, against her will, and without her
20
consent.
21
55. Plaintiff was aware of, and suffered the extreme effects of, the Defendants'
22
unlawful confinement.
23
56. As a consequence of Defendants' false imprisonment of Plaintiff, she sustained
24
conscious pain and suffering, Plaintiff's health was impaired, Plaintiff suffered great mental
25
distress, shock, fright and humiliation, and Plaintiff's reputation and character were injured.
26
57. As a consequence of the conduct of Defendants, Plaintiff has incurred severe
27
psychological trauma and damage, has suffered great humiliation, loss of esteem, mental anguish
28
and suffering.
8
COMPLAINT FOR DAMAGES
EFTA00019108

=== Page 9 ===
1
58. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. $ 214-g
2
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
3
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
4
the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. $ 130.55.
5
PRAYER FOR RELIEF
6
WHEREFORE, Plaintiff Jane Doe prays for this Court to:
7
59. Issue a judgment declaring that Defendant ESTATE OF JEFFREY E. EPSTEIN by
8
and through its executors, DARREN K. INDYKE and RICHARD D. KAHN, as legal
9
representatives of the Estate of Jeffrey E. Epstein, and Defendant GHISLAINE MAXWELL are
10
liable for the violations of law alleged in this case;
11
60. Award actual, compensatory, statutory, consequential and punitive damages;
12
61.
Award pre-judgment and post-judgment interest at the highest rate allowed by law;
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699 fax
13
and
14
62. Grant such further relief as this Court may deem just and proper.
15
Respectfully submitted,
16
R.Olas
17
Dated: January 16, 2020
Kevin Boyle (admission pending)
18
Robert Glassman (admission pending)
19
Nathan Werksman (admission pending)
20
PANISH SHEA & BOYLE LLP
11111 Santa Monica Blvd., Suite 700
21
Los Angeles, CA 90025
Telephone: (310) 477-1700
22
Facsimile: (310) 477-1699
23
boyle@psblaw.com
glassman@psblaw.com
24
werksman@psblaw.com
25
/s/ Benedict P. Morelli
Benedict P. Morelli
26
David T. Sirotkin
27
Sara A. Mahoney
28
MORELLI LAW FIRM PLLC
9
COMPLAINT FOR DAMAGES
EFTA00019109

=== Page 10 ===
1
777 Third Avenue, 31st Floor
New York, NY 10017
2
Telephone: (212) 751-9800
3
Facsimile: (212) 751-0046
bmorelli@morellilaw.com
4
dsirotkin@morellilaw.com
smahoney@morellilaw.com
5
Attorneys for Plaintiff
6
7
8
9
10
11
fax
12
PANISH SHEA & BOYLE LLP
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone 310.477.1699
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
10
COMPLAINT FOR DAMAGES
EFTA00019110


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=== Page 1 ===
From:
,
(USANYS)"
To:
(USANYS)"
Subject: FW: Letter re GM Flashlight Checks
Date: Wed, 05 May 2021 13:08:33 +0000
Attachments: 2021.04.29_AJN_Order_re_GM_Sleeping_Conditions.pdf;_2021-05-
04_GM_letter_re_flashlight_checks_v2.docx
From:
(USANYS)
Sent: Tuesday, May 4, 2021 7:52 PM
To:
(USANYS)
is
(USANYS)
Cc:
>;
Subject: Letter re GM Flashlight Checks
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:
EFTA00019912


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 28, 2019
By ECF and E-Mail
Honorable Richard M. Berman
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully writes in response to legal arguments raised by defense counsel
at the August 27, 2019 hearing on the Government's nolle prosequi motion. As set forth below,
the Court must dismiss the Indictment where, as here, the defendant has died prior to a conviction
becoming final. Moreover, the Court does not have the authority, inherent or otherwise, to conduct
its own inquiry into the circumstances of Jeffrey Epstein's suicide, or to supervise the ongoing
Grand Jury investigation.
1. The Rule of Abatement Requires the Dismissal of the Indictment
As the Court is aware, clear Second Circuit precedent requires the dismissal of an
indictment when a defendant dies before his conviction becomes final, under the "well-settled rule
that actions upon penal statutes do not survive the death of the wrongdoer." United States V.
Wright, 160 F.3d 905, 908 (2d Cir. 1998) (internal citation omitted). This rule applies with full
force here, and requires the dismissal of the Indictment. See Transcript of Aug. 27, 2019 Hearing
("Tr.") at 9 (Court noting that "it is appropriate to conclude that if the rule of abatement applies to
a convicted defendant as in the Wright case, it should also apply a fortiori in the Epstein case,
which was still in the pretrial phase when Mr. Epstein died, when there had been no conviction.");
see also United States V. Brooks, 872 F.3d 78, 87 (2d Cir. 2017), cert. denied, 139 S. Ct. 171, 202
L. Ed. 2d 37 (2018) ("This general rule, almost unanimously followed by the federal Courts of
Appeals, has its roots in the common law doctrine of abatement ab initio: "everything associated
with the case is extinguished, leaving the defendant as if he had never been indicted or
convicted.") (collecting cases).
2. The Court Does Not Have the Authority to Conduct its Own Investigation
At yesterday's hearing, defense counsel posited that the "court has the inherent authority
to find out what happened on its watch," and asked the Court to "supervis[e], or at least keep an
EFTA00020085

=== Page 2 ===
Page 2
interest in these proceeding[s]." (Tr. 17-18). Defense counsel is wrong. The Court lacks the
constitutional authority to supervise a grand jury investigation or to appoint an independent
prosecutor to investigate the circumstances surrounding Epstein's death. The only power the
Constitution permits to be vested in federal judges is "[t]he judicial power of the United States,"
Art. III, $ 1, which is the power to decide, in accordance with law, who should prevail in a case or
controversy, see Art. III, $ 2. That power does not include "supervisory" authority" over the grand
jury-"an institution separate from the courts, over whose functioning the courts do not preside."
United States V. Williams, 504 U.S. 36, 45-46 (1992); see also United States V. Dionisio, 410 U.S.
1, 17-18 (1973) (holding that the grand jury must remain "free to pursue its investigations
unhindered by external influence or supervision so long as it does not trench upon the legitimate
rights of any witness called before it."). To allow a court to supervise a grand jury's investigation
would also likely conflict with the Fifth Amendment's constitutional guarantee of "an investigative
body acting independently of either prosecuting attorney or judge." Williams, 504 U.S. at 49
(quoting Dionisio, 410 U.S. at 16).
The court's judicial power also "does not include the power to seek out law violators in
order to punish them" and, accordingly, it is "well established that the judicial power does not
generally include the power to prosecute crimes." Young V. U.S. ex rel. Vuitton et Fils S.A., 481
U.S. 787, 816-17 (1987) (Scalia, J., concurring) (citing United States V. Cox, 342 F.2d 167 (5th
Cir. 1965), and United States V. Thompson, 251 U.S. 407, 413-17 (1920)). Rather, the Constitution
vests the power to conduct investigations and prosecute violations of the laws in the Executive.
See Art. II, § 2, cl. 1; Heckler V. Chaney, 470 U.S. 821, 832 (1985); Buckley V. Valeo, 424 U.S. 1,
138 (1976). Indeed, the Second Circuit has emphasized that judicial review and regulation of
prosecutorial decisions would place courts in the "injudicious posture of becoming
"superprosecutors," and would invite questions about "the judiciary's role of supervision,"
including "[a]t what point would the prosecutor be entitled to call a halt to further investigation,"
"[w]hat evidentiary standard would be used." Inmates of Attica Corr. Facility V. Rockefeller, 477
F.2d 375, 380 (2d Cir. 1973) (discussing action to require federal officials to investigate and
prosecute persons who had allegedly violated criminal statutes).
For those reasons, among many, a judge's authority to initiate a proceeding and appoint an
attorney to conduct an investigation has been circumscribed by Congress and the Supreme Court.
Only when a court order has been disobeyed does a court "possess inherent authority to initiate
contempt proceedings." Young, 481 U.S. at 793. But, even in the unique context of criminal
contempt-which is not at issue here-a court only has authority to appoint a private lawyer to
prosecute the contempt where the United States Attorney has refused the prosecution. See Fed. R.
Crim. P. 42(a)(2).
The precedent cited by defense counsel-the special proceeding initiated by Judge Emmett
Sullivan following the dismissal of the prosecution of Senator Ted Stevens-provides no authority
for the exercise of the court's power here. See In re Special Proceeding, Misc. No. 09-0198 (EGS).
In that case, after the Department of Justice dismissed the charges against Senator Stevens for
apparent Brady violations, Judge Sullivan, pursuant to Rule 42, appointed a special prosecutor to
investigate the violations. See United States V. Stevens, No. 08 Cr. 231 (EGS) (Apr. 8, 2009) (Dkt.
No. 375); Reporter's Transcript of Proceedings, United States V. Stevens, No. 08 Cr. 231 (EGS),
EFTA00020086

=== Page 3 ===
Page 3
at 46-47 (Apr. 7, 2009). But here, there is no allegation of disobedience of court order that would
give the court authority to initiate a proceeding under Rule 42, or appoint a private attorney.
Finally, it bears noting that the United States Attorney's Office, Federal Bureau of
Investigation, and Department of Justice - Office of Inspector General are conducting an ongoing
Grand Jury investigation into the circumstances surrounding Epstein's August 10, 2019 suicide.
A separate investigation would likely, at best, be redundant and may risk undermining the existing
investigation.
Accordingly, for the foregoing reasons, we respectfully request that the Court grant
Government's nolle prosequi motion.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
by:
/s/
Assistant United States Attorneys
EFTA00020087


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 29, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed are witness materials, Government Exhibits, and discovery pertinent to the following
inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
United States Attorney
by:
/s
Assistant United States Attorneys
Enclosure
EFTA00019059


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=== Page 1 ===
From:
To:
Subject: Action shot from Florida Daily Post
Date: Mon, 22 Jul 2019 18:38:22 +0000
Attachments: Deemed-Dangerous-Epstein-Denied-Bail-in-Sex-Abuse-Casejpg
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00020343


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=== Page 1 ===
From:
)"
To: "Besselsen, Daniel"
Cc:
)"
(NY) (FBI)"
Subject: RE: [EXTERNAL] Re: travel
Date: Fri, 19 Nov 2021 15:19:59 +0000
Hi Dan,
Thanks a lot for sending us these. We don't need the other applications for the student in GX 742, but thank you for
offering.
Thanks again, and have a nice weekend,
From: Besselsen, Daniel
Sent: Thursday, November 18, 2021 11:49 AM
To:
Cc:
is
(NY) (FBI)
>; ; Daniel Besselsen
Subject: Re: [EXTERNAL] Re: travel
Hi
See attached as requested for GX 742 and 743. I included all the pages in the attachments, those pages that you had
previously and the few new pages. I also included a current picture of the "Epstein Scholarship Lodge" on our campus
which was renamed "Green Lake Lodge".
Per my previous email, if you are also interested in the summer Camp 1997 application and highschool school year 1999-
2000 application for the student in GX 742 just let me know and I can get those to you too.
Let me know if you have any follow up questions, thanks.
Dan Besselsen, CPA
Assistant Vice President of Finance
Interlochen Center for the Arts
W: interlochen.org
Arts Camp Arts Academy I College of Creative Arts Presents Public Radio
On Wed, Nov 17, 2021 at 7:25 PM
wrote:
Hi Dan,
Following up on our conversation, we would appreciate it if you would send us the rest of the admissions file for the
students in GX 742 and 743. No need to send us the rest of the materials in GX 741.
Thanks again,
EFTA00019438

=== Page 2 ===
From: Besselsen, Daniel
Sent: Thursday, November 11, 2021 5:18 PM
To:
Cc:
is
(NY) (FBI)
Subject: [EXTERNAL] Re: travel
Hi
Yes, certainly. See below:
Thanks.
Dan Besselsen, CPA
Assistant Vice President of Finance
Interlochen Center for the Arts
W: interlochen.org
Arts Camp I Arts Academy I College of Creative Arts I Presents I Public Radio
On Thu, Nov 11, 2021 at 2:52 PM
>
wrote:
Hi Dan,
Thanks very much for speaking with us today. Could you please send me the following information for your travel? I'll
pass this along to our witness coordinator, who will be in touch with you to make arrangements.
Name as it appears on the government ID you'll be using to travel
Date of birth
Home address
Phone number
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00019439


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: Maxwell detention hearing
Date: Fri, 10 Jul 2020 13:15:26 +0000
Attachments: 2020.07.09_Scheduling_Order.pdf
Hi
Attached is the Court's order setting out the logistics for the upcoming bail hearing for Maxwell. It has the dial-in
information for the public access to the audio feed of the proceeding, in case any victims reach out asking for it.
Thanks,
EFTA00020392


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=== Page 1 ===
From: White Collar Law360 <news@law360.com>
To:
Subject: Toyota Probed Possible Bribes To Top Thai Judges
Date: Tue, 30 Mar 2021 07:44:32 +0000
Law360 White
Collar
WHITE COLLAR
Tuesday, March 30, 2021
Follow Law360
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Toyota Probed Possible Bribes To Top Thai Judges
More than six months before Toyota disclosed concerns to U.S. authorities
Law360 Rising Stars
about possible foreign bribery in Thailand, the automaker launched its own
investigation into whether its consultants paid off Thai judges and
government officials in an effort to overturn a $350 million import tax
judgment related to its Prius cars, according to company documents and
sources familiar with the matter.
Read full article
2nd Circ. Won't Lift Donziger's House Arrest Before Trial
The Second Circuit refused Friday to overturn rulings keeping Chevron foe
Steven Donziger in home confinement while he awaits a May trial, rejecting
his arguments that he's not a flight risk since he's been home for over a year
over a contempt charge that has a maximum six-month sentence.
Order attached Read full article
EDNY To Increase Resources Amid Asian Hate Crime Spike
LAW FIRMS
The U.S. Attorney's Office for the Eastern District of New York said Monday
Aidala Bertuna
that it's doubling the size of the civil rights section in its criminal division, as
Caldwell Cassady
law enforcement grapples with the pronounced spike in anti-Asian hate
Cohen & Gresser
crimes amid the COVID-19 pandemic.
Cole Schotz
Read full article
Cravath Swaine
Crowell & Moring
Justices Won't Hear Request To Make Clinton Be Deposed
DLA Piper
The U.S. Supreme Court on Monday rejected a conservative group's petition
Davis Polk
for the justices to revive its demand that Hillary Clinton face deposition over
her use of a private email server as secretary of state.
Fick & Marx
Read full article
Gordon & Rees
Haddon Morgan
Feds Seize Websites Posing As COVID-19 Vaccine Makers
Kaufman Dolowich
U.S. authorities have seized seven websites that masqueraded as places
Kirkland & Ellis
where people could learn information about COVID-19 vaccines, warning that
Latham & Watkins
fraudsters are exploiting interest in the injections to lure victims into divulging
personal data.
Law Offices of Joseph A. Bondy
Read full article
Linklaters
McGuireWoods
Ghislaine Maxwell Hit With New Child Sex Trafficking Charges
McKool Smith
Ghislaine Maxwell, accused of grooming underage girls for sex with the late
Merson Law PLLC
financier Jeffrey Epstein, was hit with child sex trafficking charges for the first
Morgan Lewis
EFTA00019088

=== Page 2 ===
time on Monday in a new indictment alleging that she recruited and paid a
Morris Nichols
14-year-old victim.
Potter Anderson
2 documents attached
Read full article
Potter Handy
Parnas Bail Relaxed As Court Eyes Selective Prosecution Row
Price Benowitz
A Manhattan federal judge on Friday loosened bail conditions for Lev Parnas,
Ropes & Gray
the Florida associate of former President Donald Trump's lawyer Rudy
Schulte Roth
Giuliani, amid filings by Parnas' defense team claiming charges against him
stem from a politically motivated selective prosecution.
Selendy & Gay
Order attached Read full article
Seward & Kissel
Seyfarth Shaw
Man Accused Of Threatening Flynn Judge Reaches Plea Deal
Spence & Becker
A New York man will plead guilty to charges that he threatened to assault and
Susanin Widman
murder a D.C. federal judge who oversaw the criminal case of President
Weil Gotshal
Donald Trump's former national security adviser Michael Flynn, a federal
prosecutor revealed on Monday.
White & Case
Read full article
Wilkinson Stekloff
Williams & Connolly
Weinstein Accusers Get Case Paused To Attempt Mediation
Wilmer Hale
A New York federal judge on Monday stayed a sexual assault case against
convicted rapist Harvey Weinstein, after the four women filing suit told the
COMPANIES
judge they were taking their claims against the disgraced movie mogul to
Amazon.com Inc.
mediation.
American Arbitration Association
Proposed Rule attached Read full article
American Bar Association
American Civil Liberties Union
SECURITIES
Apple Inc.
Ex-Engine Maker Execs Can't Ditch SEC's Fraud Suit
Bank of America Corp.
An Illinois federal judge on Monday refused to toss a U.S. Securities and
Boehringer Ingelheim Vetmedica
Exchange Commission lawsuit accusing an alternative-energy engine
Inc.
maker's former executives of engaging in an accounting fraud scheme that
Boston Scientific Corp.
inflated company revenues by $25 million.
C.R. Bard Inc.
Opinion attached Read full article
Chevron Corp.
Deutsche Bank AG
BANK FRAUD
Dick's Sporting Goods Inc.
Ex-Madoff Funds Can't Ditch Deutsche Bank's Contract Fight
Facebook Inc.
A New York federal judge on Friday denied a bid by former Bernie Madoff
Georgetown University
feeder funds to end Deutsche Bank Securities Inc.'s lawsuit accusing them of
International Business Machines
breaching a 2011 agreement to sell the bank's bankruptcy claims that were
Corp.
once worth $1.6 billion, finding that the bank's allegations are sufficient to
Johnson & Johnson
proceed.
Judicial Watch Inc.
2 documents attached Read full
article
Kinney Recruiting LLC
LexisNexis Group
TRIALS
Madison Square Garden
Architect In Tribal Bribery Suit Has Designs On Quick Trial
Entertainment Group LLC
An architecture firm owner accused of bribing the former chairman of a
Marriott Vacations Worldwide Corp.
Massachusetts tribe said Friday that new tax charges filed against his co-
Marvell Technology Group Ltd.
defendant shouldn't delay a jury trial, telling a federal judge that bad publicity
Match Group Inc.
from the case is killing his business.
McDonald's Corp.
Motion attached Read full article
Microsoft Corp.
Miramax Film Corp.
Deal Eyed In Fight Over Virtual Pittsburgh Court Access
Pfizer Inc.
A civil rights watchdog said Monday it was giving a Pennsylvania state judge
Power Solutions International Inc.
three weeks to show he was complying with a new order mandating virtual
access to criminal proceedings in Pittsburgh before potentially dropping a
PricewaterhouseCoopers LLP
lawsuit accusing him of unconstitutionally shutting the public out of hearings.
State Bar of California
Read full article
Steelcase Inc.
EFTA00019089

=== Page 3 ===
HEALTH
The Walt Disney Co.
Thomson Reuters Corp.
Insys Brass Knew Opioid Scripts Were Bogus, 1st Circ. Told
Toyota Motor Corp.
A group of convicted Insys Therapeutics Inc. executives knew when they
Twitter Inc.
bribed doctors to prescribe opioids that some of the powerful drugs would go
United Auto Workers
to people who didn't need them, federal prosecutors told the First Circuit in a
bid to reinstate part of a landmark guilty verdict.
VirnetX Holding Corporation
Brief attached Read full article
YouTube Inc.
GOVERNMENT AGENCIES
NJ Judge Won't Toss Health Plan Enrollment Fraud Claims
A former union official, a shell company founder and an accountant must face
California Supreme Court
a lawsuit over an alleged scheme to defraud an autoworkers' health benefits
Centers for Disease Control and
fund out of millions of dollars, according to a New Jersey federal judge.
Prevention
Opinion attached Read full article
Central Intelligence Agency
Federal Bureau of Investigation
EXPERT ANALYSIS
Financial Crimes Enforcement
Network
Safeguarding Privileged Communications In A Remote World
International Monetary Fund
With the pandemic ushering in remote collaboration tools, counsel must
Mashpee Wampanoag Tribe
revisit fundamentals of the attorney-client privilege and the work-product
New York City Police Department
doctrine, study cases involving email and other recent technologies, and
follow 10 best practices to protect confidentiality, say attorneys at DLA Piper.
New York State Commission on
Judicial Conduct
Read full article
Pennsylvania Supreme Court
U.S. Attorney's Office
Law360
U.S. Attorney's Office for the
District of Massachusetts
LEGAL INDUSTRY
U.S. Attorney's Office for the
Eastern District of New York
Bonus Spotlight
U.S. Attorney's Office for the
4 More BigLaw Firms Pay Another COVID-19 Bonus
Southern District of New York
Weil Gotshal & Manges LLP, Ropes & Gray LLP, Morgan Lewis & Bockius
U.S. Court of Appeals for the First
LLP and Linklaters LLP will be distributing spring and fall bonuses to their
Circuit
associates for work during the pandemic, the firms confirmed Monday.
U.S. Court of Appeals for the
Read full article
Second Circuit
U.S. Department of Homeland
Titan Of The Plaintiffs Bar: Caldwell Cassady's Brad Caldwell
Security
One would never show their playbook to an opponent before a football game,
U.S. Department of Justice
but Brad Caldwell says that's pretty much what has happened since he
represented VirnetX in the first of several trials against Apple nearly a decade
U.S. District Court for the District of
ago. He's won each time by largely sticking to a consistent storyline, most
Columbia
recently securing a $502.8 million verdict for his client in the companies' fifth
U.S. District Court for the District of
trial in October.
Delaware
Read full article
U.S. District Court for the District of
Massachusetts
McDonald's Taps Boston Scientific Atty As New GC
U.S. District Court for the District of
McDonald's announced Monday that the fast food giant has appointed a
New Jersey
Boston Scientific Corp. attorney as its new general counsel and corporate
U.S. District Court for the Eastern
secretary.
District of Louisiana
Read full article
U.S. District Court for the Northern
District of Illinois
NY Judge Scolded For Facebook Photos In Cop Uniform
U.S. District Court for the Northern
The New York State Commission on Judicial Conduct said Monday it formally
District of Texas
admonished a local judge for posting to Facebook photos of himself in a
U.S. District Court for the Southern
police officer's uniform, actions the commission said call his objectivity into
District of New York
question in cases involving law enforcement.
Read full article
U.S. District Court for the Western
District of Pennsylvania
EFTA00019090

=== Page 4 ===
IMF Beats Suit Filed By Own Legal Team Thanks To Immunity
U.S. District Court for the Western
A D.C. federal judge has granted the International Monetary Fund's request
District of Washington
to dismiss a suit filed by its longtime legal counsel challenging the validity of
U.S. Securities and Exchange
an arbitral award for legal fees, finding that the IMF is immune from the suit.
Commission
Read full article »
U.S. Supreme Court
United Nations
ROSS Can't Toss IP Suit Claims It Stole Westlaw Content
United States District Court for the
Legal research startup ROSS Intelligence can't dismiss copyright claims from
District of Colorado
Thomson Reuters that the former illegally copied huge swaths of the Westlaw
database to create a competing service, a Delaware federal judge ruled
World Bank Group
Monday.
World Health Organization
Read full article »
Atty Recruiter Says Ex-Firm's Suit Targets Biz He Built Alone
An attorney recruiter battling his former employer over alleged trade secret
theft told a Texas federal court Friday he built his Asia-focused business
"from the ground up" and should see the claims against him thrown out.
Read full article
Suspended Atty Wants Court Review Of Calif. Bar Speech Rule
An attorney suspended from practicing law in California has petitioned the
U.S. Supreme Court to review whether a state bar may punish him for
statements deemed false but also found to be harmless, arguing that the
decision to suspend him places unconstitutional limits on advocacy speech
from lawyers.
Read full article »
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=== Page 1 ===
Event: Accepted: Epstein call
Start Date: 2019-01-11 16:00:00 +0000
End Date: 2019-01-11 16:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-01-09 17:00:34 +0000
Date Modified: 2019-01-09 17:00:34 +0000
Priority: 5
DTSTAMP: 2019-01-09 16:54:52 +0000
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
i
(USANYS)"
Subject: FW: U.S. V. Maxwell 20 Cr. 330 (AJN)
Date: Tue, 23 Feb 2021 19:54:24 +0000
Attachments: MAXWELL_BAIL_APPLICATION_with_EXHIBIT_2-23-17.pdf
FYI
From: BOBBI C STERNHEIM
Sent: Tuesday, February 23, 2021 2:44 PM
To:
)
is
)
is
(USANYS)
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: U.S. V. Maxwell 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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.
EFTA00018708


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=== Page 1 ===
From: Chris Dilorio
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Tue, 03 Nov 2020 22:37:11 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
From: Chris Dilorio
Sent: Friday, October 30, 2020 6:20 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Friday, October 30, 2020 6:16 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings Janey, grossly corrupt SEC et al.
The fraud on the SDNY courts perpetrated by the grossly corrupt SEC is staggering. Like me, Dan Kamensky
never had a chance going up against the Mogilevich Bag Man Milken flunkie degenerate crew.
Phat Leon Black: Apollo as I have previously stated: very high on the SEC/DoJ "Do Not Investigate List". Milken's
"right hand man at Drexel". Black, his family/Apollo controlled the ONLY Epstein SEC disclosed money
EFTA00019148

=== Page 2 ===
laundering shell called Environmental Solutions World Wide (ESWW).
In 2002 the SEC brought a complaint against ESWW: Fraud. With money laundering flags too numerous to
count. But, in typical SEC Cover up mode: no AML complaint.
https://www.sec.gov/litigation/litreleases/Ir17673a.htm
Environmental Solutions Worldwide, Inc. et al.: Lit. Rel. No. 17673a /
August 13, 2002 - SEC
UNITED STATES SECURITIES AND EXCHANGE COMMISSION. Litigation Release No. 17673A / August 13,
2002 SEC Files Civil Lawsuit in $15 Million "Pump and Dump" Stock Fraud Case
www.sec.gov
So, Black, his family, and Apollo KNEW ESWW was an OTCM money laundering shell when it "invested" along
side Epstein. But, Phat Leon, his family, Apollo didn't just own ESWW stock, they controlled the company
https://in.reuters.com/finance/stocks/company-officers/ESWW.PK
Stock Quote News - Stock Market Quotes,
Online Stock Quotes, India
Reuters India provides latest news & articles on stock market
quotes, online stock quotes, India. Get India stock market quotes,
stock quote news india, latest share prices for ESWW.PK
in.reuters.com
The SEC kept ESWW up and running for 13 years AFTER it filed its complaint while Black/his
family/Apollo/Epstein laundered millions of dollars through this SEC declared "scam". In the end, ESWW wasn't
even revoked. Rather: voluntarily withdrawn.
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
EFTA00019149

=== Page 3 ===
The ESWW CEO/Chairman was a guy named Mark Yung
Dually employed at a firm called Orchard Capital while at ESWW
Orchard was controlled by Richard Ressler. Another Mogilevich Bag Man Milken Drexel flunkie Degenerate.
Ressler went on to found Ares Management. Which, with the blessing of the SEC went public in 2014
https://www.sec.gov/cgi-bin/browse-edgar?CIK=1176948&owner=exclude
Ares/Ressler bought Neiman Marcus in 2013
https://www.reuters.com/article/us-neimanmarcus-ares-idUSBRE9880OZ20130909
Neiman Marcus sold for $6 billion to Canada
Pension Plan, Ares | Reuters
The owners of Neiman Marcus Inc <NMRCUS.UL> agreed to sell
the U.S. luxury department store chain to two private investors for
$6 billion, almost $1 billion more than they paid for the company
in
www.reuters.com
One of these things is not like the others: Dan Kamensky is NOT on the Milken et al SEC/DoJ "Do not
investigate list". He never had a chance. Kamensky was an outsider in a process only available to Milken flunkie
degenerates. ESWW: a money laundering OTCM shell. Leon Black? His family? Apollo? Epstein? Yes SDNY
and grossly corrupt SEC: Junk is junk. Milken is the nexus of ALL of it. Obviously, I'm not in the inner circle
either Mr Kamensky. I blew the whistle on a massive, SEC facilitated fraud on the public that is very much
ongoing. The SEC has KNOWINGLY used the SDNY courts to perpetuate this massive fraud prosecuting some
while corruptly and criminally obstructing prosecution of KNOWN criminals. AND screwing those who blow
the whistle and dare challenge: Dan Kamensky and Chris Dilorio.
Happy Friday!
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Monday, May 6, 2019 6:38 AM
To:
EFTA00019150

=== Page 4 ===
<sabellac@sec.gov>
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings grossly corrupt SEC et al scumbags
As with ALL of my allegations: beyond a shadow of a doubt, 100% accurate
https://www.sec.gov/litigation/complaints/comp17673.htm
Complaint: SEC V.
COMPLAINT. Plaintiff United States Securities and Exchange Commission ("Commission") alleges as
follows: SUMMARY. 1. This case involves a $15 million "pump and dump" scheme involving the securities
EFTA00019151

=== Page 5 ===
of Environmental Solutions Worldwide, Inc. ("Environmental"), a public company whose common stock is
registered with the Commission under the Securities Exchange Act of 1934 ("Exchange Act"), and is
www.sec.gov
ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken
proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it.
IG, I have repeatedly offered to come to SEC DC HQ to have the brightest minds at the SEC totally humiliate me
by refuting my allegations 1 by 1. The grossly corrupt SEC scumbags have never taken me up on my generous
offer. For the very simple reason that ALL of my allegations are accurate and true.
So, I again put the offer out there:
refute my claims OR go to jail for the criminal obstruction ACTIVELY being facilitated by your office and the SEC.
So, let's give these scumbags the insurance/annuities market.
This will NOT end well for tens of thousands of Americans.
Who "green lighted" this take over of the insurance industry by PE/Hedge funds?
https://www.forbes.com/sites/antoinegara/2018/02/01/apolo-and-blackstone-pick-insurance-as-their-next
bet-to-disrupt-wall-street/#5d647dbe7689
Apollo And Blackstone Pick Insurance As Their
Next Bet To Disrupt Wall Street - Forbes
For decades, Wall Street's gambit in insurance was to write
policies and use the float as a source of capital for new
investments. It's a staple of Berkshire Hathaway and copycats like
Markel and
www.forbes.com
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 2, 2019 3:35 PM
To:
EFTA00019152

=== Page 6 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tells-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Diiorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
To:
EFTA00019153

=== Page 7 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) | Seeking
Alpha - Stock Market Insights I Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
EFTA00019154

=== Page 8 ===
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, April 14, 2019 1:04 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
EFTA00019155

=== Page 9 ===
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-i-joins-wilmerhale.
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
EFTA00019156

=== Page 10 ===
SEC.gov
|
Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
To:
Subject: Apollo/ Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
EFTA00019157

=== Page 11 ===
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.htm)
EFTA00019158

=== Page 12 ===
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
---
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports.
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
EFTA00019159

=== Page 13 ===
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00019160


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein suicide -- counseling for victims?
Date: Sat, 10 Aug 2019 19:21:38 +0000
With apologies for the weekend email, we have gotten questions from counsel about whether there is any availability for
crisis (or other immediate or near-term) counseling for victims, given Epstein's death? My sense is that some victims may
be struggling with the idea that their accusations could remain unvindicated as a result of these events. Is there any
information we might be able to pass along to them and/or their counsel? I'm also free to discuss via phone if that's
helpful
). Thank you very much!
Assistant U.S. Attorney
Southern District of New York
EFTA00019766


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
Cc: Christian Everdell
Subject: Ghislaine Maxwell 02879-509
Date: Thu, 02 Sep 2021 19:22:09 +0000
Attachments: 127129690648.pdf; ATT00001.htm
Good afternoon-
In compliance with the Court's order, dated August 25th (attached), I hereby notify you
of recent third-party interference with the "secure" Webex line used for confidential/privileged communication
between Ms. Maxwell and counsel.
At the conclusion of yesterday afternoon's VTC session, Ms. Maxwell observed
suspicious activity on the VTC monitor.
She alerted MDC staff, and Case Manager
witnessed the activity.
This is contrary to the Court's finding that "according to the Government and MDC Legal [Ms. Maxwell]'s
difficulties communicating with counsel have been resolved" and contrary to "MDC's Legal assurances that [Ms.
Maxwell]'s legal communication has not been interfered with..."
Previously, the MDC has disputed such claims concerning interference with
VTC communication between Ms. Maxwell and counsel.
Now, an MDC insider bears witness to complaint by Ms. Maxwell and counsel.
Please provide explanation for this interference and evidence of remediation
before I report this latest problem to the Court.
Thank you-
Bobbi
EFTA00017847


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=== Page 1 ===
From:
To:
Ce:
Subject: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Date: Mon, 21 Dec 2020 14:52:46 +0000
Hi
Per my voicemail-
Maxwell was informed she has no legal calls today.
We understood she would have daily (M-F) VTCs from 12:30-3:30 as she did on Friday.
Please confirm.
Thank you-
Law Offices of
New York, NY 10011
Main
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Dec 16, 2020, at 2:47 PM,
rote:
Understood.
Many thanks!
Best-
Law Offices of
New York, NY 10011
Mair
Celli
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Dec 16, 2020, at 1:43 PM,
wrote:
thank you. We will not be able to do them on weekends and holiday but M-F (business days) will be fine.
V
12/16/2020 1:39 PM >>>
Good afternoon-
Following up on this morning's conversation-
Ms. Maxwell is requesting daily legal VTCs from 12:30 - 3:30 pm
to replace legal audio calls.
Should the VTC connection fail, we request that the call be reverted to
audio during the remaining time period.
EFTA00019307

=== Page 2 ===
Please call with any questions:
Thank you again for your assistance.
Best-
Law Offices of
New York, NY 10011
Mail
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Dec 16, 2020, at 10:32 AM,
wrote:
it is going straight to voicemail. Just left a message.
Nicole
>>>
12/16/2020 10:31 AM >>>
Yes-
I am available til 11:15.
10
Thanks-
Law Offices of
New York, NY 10011
Mair
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Dec 16, 2020, at 9:54 AM,
wrote:
Do you have time for a quick call, just want to run through some logistics.
>>>
12/15/2020 12:38 PM >>>
12:30 -3:30 but we are flexible.
Much appreciated.
Law Offices of
New York, NY 10011
Main
Cell:
Fax:
EFTA00019308

=== Page 3 ===
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Dec 15, 2020, at 11:48 AM,
vrote:
Is there a specific time and length you are looking for?
^^^
12/15/2020 11:46 AM
Thank you for your assistance in arranging legal video conferencing for Ms. Maxwell
We request daily VTCs.
It is my understanding that there is a VTC terminal in the vicinity of Ms. Maxwell's
isolation cell and day room area.
Please let me know if I need to arrange these through the MDC legal conferencing portal managed by FDNY.
Much appreciated.
Best-
Law Offices of
New York, NY 10011
Mai
Cell
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Dec 15, 2020, at 10:16 AM,
wrote:
Apologies for not getting back sooner. Let us know when you would like to schedule these.
2/10/2020 6:20 PM
Hi all-
Trying to navigate the logistics of this and will try to get back to you tomorrow with an answer on how to schedule.
12/10/2020 4:59 PM
Good afternoon-
I write again regarding my immediate need for video teleconferencing
with my client GHISLAINE MAXWELL 02879-509 (SEE EMAIL BELOW).
I am informed that in-person legal visiting has been suspended
due to the COVID outbreak at the facility.
It is imperative that I be able to review discovery documents with my client with via video.
Legal calls are insufficient for review of the millions of documents in this case.
Please make these arrangements immediately
or provide a response that I can bring to the Court's attention.
Thank you-
Law Offices of
New York, NY 10011
Main
EFTA00019309

=== Page 4 ===
Cell:
Fax:
On Dec 9, 2020, at 2:24 PM, B
wrote:
Good afternoon-
I am counsel for GHISLAINE MAXWELL 02879-509
I have requested but have never received video calls with my client Ghislaine Maxwell.
and
informed the Court that Ms. Maxwell
was provided one video call, which I confirmed occurred on August 18th but failed due to audio problems.
I am informed that the VTC occurred in a room between Ms. Maxwell's isolation cell and day room.
Yesterday, I was informed of the following-
"Unfortunately there are no VTCs on East SHU. You may reach out to
and
for further assistance in this matter."
I am requesting that videoconferences be arranged for Ms. Maxwell or provide explanation for review by the Court.
Thank you.
On Dec 8, 2020, at 3:45 PM,
wrote:
Hello
We can get you an hour long call on Thursday and do our best to make it recurring. Unfortunately there are no VTCs on East SHU. You may reach out to
and
for further assistance in this matter.
Thank you.
From:
Sent:
To:
Subject: URGENT REQUEST-GHISLAINE MAXWELL 02879-509
Hi
Requesting assistance to arrange legal calls with my client Ghislaine Maxwell 02879-509.
No response for request for visit (not sure if legal visiting suspended due to COVID outbreak.)
Am up against a filing deadline and need to review voluminous discovery with client.
Any chance for VTCs so I can review discovery client?
Otherwise daily legal calls?
Thanks for all your assistance.
New York, NY 10011
Mair
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation
Thank you for your consideration Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Nov 25, 2020, at 2:41 PM, H
vrote:
Hi
My client Ghislaine Maxwell 02879-509 is in quarantine; all of her in-person legal visits have been cancelled.
Any assistance you can provide arranging daily legal calls any time of the day - and an occasional VTC
(which has been requested but never arranged) would be greatly appreciated.
This case involves voluminous discovery (the latest production is 1.2 million documents) and upcoming filing deadlines.
It is imperative that I have contact with my client.
EFTA00019310

=== Page 5 ===
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: US V. Epstein
Date: Tue, 10 Sep 2019 16:26:34 +0000
The data from the hard drive has been loaded to Relativity and has been secured for privilege review.
Thank you.
From:
Sent: Thursday, August 29, 2019 11:12 AM
To:
Cc:
is
Subject: Re: US V. Epstein
Thanks
Assistant United States Attorney
Southern District of New York
One St. Andrews Plaza
New York, NY 10007
On Aug 29, 2019, at 11:10 AM,
wrote:
Hi
The materials on the drive were extracted from devices seized from Epstein's Manhattan residence pursuant to a search
warrant.
It does not include materials seized from USVI.
Thanks,
Sent from my iPhone
On Aug 29, 2019, at 10:17 AM,
wrote:
Is the Epstein data that we are loading Search Warrant returns? And was Epstein the only custodian?
Thanks,
EFTA00019471

=== Page 2 ===
From:
Sent: Thursday, August 29, 2019 10:08 AM
To:
Cc:
Subject: US V. Epstein
Hello
Can you please let me know if there is a specific custodian for this priv review for Epstein? Also, can you please let me
know where this data should be loaded into Relativity (subpoena returns or something else)?
Thank you.
EFTA00019472


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=== Page 1 ===
Event: Epstein/Maxwell FOIA
Start Date: 2021-03-10 22:00:00 +0000
End Date: 2021-03-10 22:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2021-03-10 20:40:03 +0000
Date Modified: 2021-03-10 20:40:03 +0000
Priority: 5
DTSTAMP: 2021-03-10 20:13:35 +0000
Attendee:
)
i
(USANYS)
i
(USANYS)
i
(USANYS)
i
)
i
)
Alarm: Display the following message 15m before start
Reminder
-- Do not delete or change any of the following text. --
When it's time, join your Webex meeting here.
Join meeting
More ways to join:
Join from the meeting link
EFTA00017896

=== Page 2 ===
https://usao.webex.com/usao/j.php?MTID=mc1bb5eed0ec0ce74c174ac88e8ccbd53
Join by meeting number
Meeting number (access code): 199 962 1511
Meeting password: PMxMsPua532
Tap to join from a mobile device (attendees only)
1999621511## USA Toll 2
,1999621511## US Toll
Join by phone
USA Toll 2
US Toll
Global call-in numbers
Join from a video system or application
Dial 1999621511@usao.webex.com
You can also dial 207.182.190.20 and enter your meeting number.
Join using Microsoft Lync or Microsoft Skype for Business
Dial 1999621511.usao@lync.webex.com
If you are a host, click here to view host information.
Need help? Go to https://help.webex.com
EFTA00017897


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald
Date: Sat, 01 Dec 2018 00:05:54 +0000
Importance: Normal
Yes. As of today. On the d/l for now.
Sent from my iPhone
> On Nov 30, 2018, at 6:56 PM,
wrote:
>
> Are we open on this? Can we be?
>
>
https://www.miamiherald.com/news/local/article220097825.html
EFTA00018650


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=== Page 1 ===
From:
)"
To:
Subject: Fwd: travel approval request
Date: Fri, 13 Dec 2019 19:22:28 +0000
Thanks! This request is just for me, not sure what arrangements other folks are making. Thanks.
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: December 12, 2019 at 6:10:22 PM EST
To:
Cc:
)"
Subject: FW: travel approval request
Hi
In connection with this trip, could you please assist with booking the following travel? Thanks!
Hotel-same as last time, the DoubleTree in Santa Monica is fine. Checking in 12/15, checking out the next day
We do not need a conference room
Outbound flight: Sunday, 12/15, departing JFK at 11:40 am on Delta, landing at LAX at 3:01 p.m.
Inbound flight: Monday, 12/16, departing LAX at 8:32 p.m. on JetBlue, landing at JFK at 4:47 a.m.
If you could please make all flights refundable, that would be great - it's possible we'll need to rebook parts of
this if witness availability changes or we're able to stay longer and meet with an additional witness.
Thanks a bunch.
From:
Sent: Wednesday, December 11, 2019 10:01 AM
To:
Cc:
is
)
is
Subject: RE: travel approval request
Approved
From:
Sent: Wednesday, December 11, 2019 9:58 AM
To:
Cc:
is
)
is
Subject: RE: travel approval request
EFTA00019555

=== Page 2 ===
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips,
we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
)
is
A.
Alleyne
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
>;
)
is
A. Alleyne
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
)
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
EFTA00019556

=== Page 3 ===
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
> wrote:
EFTA00019557

=== Page 4 ===
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00019558


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=== Page 1 ===
****All information contained alongside this file within the ZIP container is Google Confidential an
di Proprietary****
Export Summary
Originating Identifier:
[Email Address]
Resolved Identifier:
[Google Account ID]
Resolution Path:
(Email Address] ->
[Google Account ID]
Email Address Associated with Google Account ID:
Service: Google Account
Resource: Subscriber Info
Start of date range: Not Specified.
End of date range: 2020-08-27 00:00:00 UTC
EFTA00019642


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: CBP Question
Date: Tue, 21 Sep 2021 15:14:07 +0000
Hi
absolutely!
From:
Sent: Monday, September 20, 2021 10:55 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - FW: CBP Question
Hi
Could you please take a look at these and let us know if any of these dates line up with Maxwell or Epstein's travel?
Thanks!
From:
Sent: Monday, September 20, 2021 10:49 PM
To:
Cc:
Subject: [EXTERNAL] RE: CBP Question
Hey
Attached ate the travel records as requested. However, it's the same issue as last time since the outbound departures
were not recorded during that timeframe it only shows the inbound arrivals. Any questions or concerns don't hesitate to
reach out.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
EFTA00018002

=== Page 2 ===
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws
including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and
destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may
be disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Monday, September 20, 2021 2:11 PM
To:
Cc:
Subject: RE: CBP Question
Thanks so much! Can you please pull the CBP records for
We would like the CBP records for the 1990s
only. Her date of birth is
She is French. Please let us know if you need any other information. Thanks again!
From:
Sent: Monday, September 20, 2021 1:50 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sure no problem, send over the info you need and I'll work on it today.
Sent from my iPhone
On Sep 20, 2021, at 1:42 PM,
wrote:
Hi
I hope you are doing well. We were hoping you could pull some additional CBP records for us. Are you able to assist us
with that this week?
Thanks so much,
From:
Sent: Thursday, July 29, 2021 5:31 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sorry I was on the road but I spoke with Jared he filled me in on what your looking for. I'm also available for a call to
further discuss.
Respectfully,
U.S. Customs and Border Protection
EFTA00018003

=== Page 3 ===
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable
laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the
sender and destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be
disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Thursday, July 29, 2021 3:56:15 PM
To: $
Cc:
Subject: CBP Question
CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the
sender. If you feel this is a suspicious-looking email, please report by using the Report Phish button option.
H
I hope you are well! Jared Eannucci passed along your info to us. We were hoping to connect with you by phone about
a question in one of our cases. Do you have time to talk today or tomorrow morning?
Thanks so much!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00018004


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=== Page 1 ===
From:
To:
Subject: Fwd: Times: Lawsuit Claims Epstein Trafficked Girls in Caribbean Until 2018
Date: Wed, 15 Jan 2020 21:12:49 +0000
Inline-Images: image001.jpg; image006.jpg; image007.jpg
Ms. George's lawsuit also seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr.
Epstein's vast wealth into a victim's compensatory fund. Mr. Indyke's proposal, which is currently
being litigated in a separate Virgin Islands case, imposes confidentiality on any claimants, Ms. George
said.
"The estate continues to engage in a course of conduct aimed at concealing the criminal activities of the
Epstein enterprise," the lawsuit said.
Begin forwarded message:
From:
Date: January 15, 2020 at 3:20:29 PM EST
To:
Subject: Times: Lawsuit Claims Epstein Trafficked Girls in Caribbean Until 2018
https://www.nytimes.com/2020/01/15/nyregion/jeffrey-epstein-virgin-islands.html
Lawsuit Claims Epstein Trafficked Girls in
Caribbean Until 2018
The attorney general of the Virgin Islands says Mr. Epstein and his associates used a database to
track victims as young as 11 years old.
EFTA00019223

=== Page 2 ===
A new lawsuit significantly expanded the scope of wrongdoing in which Mr. Epstein was said to have
engaged. Credit New York State Sex Offender Registry, via Associated Press
By Ali Watkins
Jan. 15, 2020Updated 2:41 p.m. ET
New evidence shows Jeffrey Epstein sexually abused and trafficked hundreds of young women and
girls on his private Caribbean island, some as recently as 2018, significantly expanding the scope of
his alleged conduct, a top law enforcement official said in a lawsuit filed on Wednesday.
Mr. Epstein, a wealthy financier who died by suicide in a Manhattan jail last year, was bringing girls
as young as 11 and 12 to his secluded estate in the Virgin Islands, known as Little Saint James, and
kept a computerized database to track the availability and movements of women and girls, the
lawsuit said.
The lawsuit, which was filed by Denise N. George, the attorney general of the Virgin Islands,
broadened the dimensions of the wrongdoing in which Mr. Epstein was said to have engaged. He had
been charged by Manhattan prosecutors in July with sexually exploiting dozens of women and girls in
New York and Florida, but they did not point to any actions beyond 2005.
In August, Mr. Epstein hanged himself at the Metropolitan Correctional Center, where he was being
held awaiting trial on federal sex trafficking and conspiracy charges. Prison guards had not checked
on him for hours on the night he died, and the circumstances surrounding his death are now the
subject of at least three federal investigations.
In the weeks before Mr. Epstein killed himself, he and his lawyers vigorously denied the criminal
charges. His lawyers had previously said he had been law-abiding since his 2008 conviction in
Florida for solicitation.
The suit was filed against Mr. Epstein's estate and seeks the forfeiture of Little Saint James and Mr.
Epstein's second private island, Great Saint James, as well as the dissolution of numerous shell
EFTA00019224

=== Page 3 ===
companies he established in the territory that officials have said acted as fronts for his sex trafficking
enterprise.
As part of its policies, the government of the Virgin Islands could take any assets recovered from Mr.
Epstein's estate and consider disbursing them to women and girls who were victimized by him in the
region, Ms. George said.
The new accusations - which draw both from independent investigations by Ms. George's office and
court documents from cases across the country - argue that Mr. Epstein ran a decades-long sex
trafficking scheme that had a primary nexus in the Virgin Islands.
Continue reading the main story
EFTA00019225

=== Page 4 ===
Image
Denise N. George, the attorney general of the Virgin Islands, is suing the estate of Jeffrey Epstein, a
wealthy financier. Credit Gabriella N. Baez for The New York Times
EFTA00019226

=== Page 5 ===
"Epstein clearly used the Virgin Islands and his residence in the U.S. Virgin Islands at Little Saint
James as a way to be able to conceal and to be able to expand his activity here," Ms. George said.
The suit underscores the legal complications of reckoning with such wide-reaching crimes as those
Mr. Epstein is said to have committed. Ms. George's suit is the first filed against the estate by a
government entity, but it joins a field of similar claims filed by more than a dozen women.
It remains unclear how Mr. Epstein's assets, which are valued at about $500 million, could be
allocated.
"We don't have a long history of figuring out what to do in cases of human trafficking," said Bridgette
Carr, the director of the Human Trafficking Clinic at the University of Michigan Law School, who
consulted with Ms. George's team on the case. "I think this litigation and the courts are just trying to
come up with the best, imperfect solution."
Mr. Epstein's executor, Darren K. Indyke, could not immediately be reached for comment.
Ms. George said she believed the case could chip away at the region's reputation as a notorious haven
for the rich and powerful.
"We will not remain complacent, and we will enforce our laws whatever way we can," Ms. George
said. "It doesn't matter the social status of the person. It's that the laws apply equally."
Image
A property on the island of Little Saint James, a private estate where Mr. Epstein is alleged to have
trafficked hundreds of girls. Credit Gabriella N. Baez for The New York Times
ADVERTISEMENT
Continue reading the main story
The court documents said that Mr. Epstein operated with impunity for years at Little Saint James
and Great Saint James, which he obtained through a straw purchaser in 2016.
As recently as July 2018, Mr. Epstein refused to permit an investigator from the Virgin Island's
Department of Justice to enter Little Saint James, claiming the island's dock was his "front door,"
according to the lawsuit. The investigator was doing routine monitoring of Mr. Epstein because he
was a registered sex offender.
Mr. Epstein's victims included aspiring models from South America, according to court documents.
EFTA00019227

=== Page 6 ===
Mr. Epstein used a ring of associates to rotate the women and girls in and out of sexual servitude,
using fraudulent modeling visas to transport them across state lines and international borders, the
lawsuit said. He tracked their availability and proximity using the database, court documents said.
The suit also said air traffic controllers in the Virgin Islands observed Mr. Epstein leaving his private
plane in 2018 with girls who looked as young as 11.
In one undated incident detailed in the lawsuit, a 15-year-old girl attempted to swim off Mr. Epstein's
island and escape after she was forced to engage in sex acts with Mr. Epstein and others. The girl was
found, and held captive on the island after he confiscated her passport, the suit said.
Prosecutors in New York have said their investigation has continued and anyone who helped Mr.
Epstein could face criminal charges.
In addition, the lawsuit said, Mr. Epstein embarked on several illegal construction projects at Great
Saint James, which caused damage to native coral and wildlife.
ADVERTISEMENT
Continue reading the main story
The more than a dozen women who have filed lawsuits against Mr. Epstein's estate in New York City
since his death have accused him of exploiting and sexually abusing them when they were young
women and girls, according to court documents. Many are seeking financial compensation.
The lawsuit in the Virgin Islands appears to be the first filed against the estate in that jurisdiction.
Mr. Epstein maintained his legal permanent residence - and his estate - there. He hastily filed his
will in a Virgin Islands court just days before he killed himself.
Ms. George's lawsuit also seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn
Mr. Epstein's vast wealth into a victim's compensatory fund. Mr. Indyke's proposal, which is
currently being litigated in a separate Virgin Islands case, imposes confidentiality on any claimants,
Ms. George said.
"The estate continues to engage in a course of conduct aimed at concealing the criminal activities of
the Epstein enterprise," the lawsuit said.
In a statement when that fund was first announced, Mr. Indyke said it would give victims "the
opportunity to obtain appropriate compensation and to be heard and treated with compassion,
dignity and respect."
EFTA00019228


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=== Page 1 ===
Event: Accepted: Epstein FOIA Moot
Start Date: 2021-04-07 20:00:00 +0000
End Date: 2021-04-07 20:30:00 +0000
Location: 844 215 6890,, 637579
Class: X-PERSONAL
Comment:
Date Created: 2021-03-26 19:44:10 +0000
Date Modified: 2021-03-26 19:44:10 +0000
Priority: 5
DTSTAMP: 2021-03-26 19:20:59 +0000
Attendee:
(USANYS)
<
EFTA00020400


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein pre-meet
Date: Sun, 07 Apr 2019 13:35:15 +0000
Importance: Normal
Attachments: unnamed
EFTA00019552


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=== Page 1 ===
From:
To:
Subject: RE: proposed schedule.
Date: Sat, 21 Sep 2019 01:09:13 +0000
I'm free that afternoon. Agree re timing.
From:
Sent: Friday, September 20, 2019 12:42 PM
To:
Subject: FW: proposed schedule.
How's next Friday to meet? That will give us a few days to discuss internally and confer with
before we meet with
them.
Assistant United States Attorney
From: Bruce Barket
Sent: Friday, September 20, 2019 12:15 PM
To:
Cc: tonyricco
; Michael Bachrach
Subject: proposed schedule.
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you can meet to
discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have ours finalized no later than
Tuesday.
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
EFTA00019694


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Fri, 30 Oct 2020 15:13:16 +0000
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference
line:
Thanks,
Alison
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
-
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
^
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
EFTA00019133

=== Page 2 ===
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still be
grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00019134

=== Page 3 ===
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com> "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow and
will have limited availability this week, but my colleagues
and
(both cc'd) should be able to
coordinate with you as needed.
Best
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019135

=== Page 4 ===
From: Jeff Jocks <jjocks@sondeeracine.com
Sent: Thursday, February 6, 2020 2:46 PM
To:
Cc:
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
=
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein
and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: hot docs
Date: Wed, 22 Sep 2021 18:41:32 +0000
Attachments: 2005-02-14_HOUSEHOLD_MANUAL.pdf
I've completed reviewing all 114 documents on the other Relativity platform for this case (FBI files, etc.). There are some
FedEx business records certificates, in case that's useful. I found the handbook from
which is attached for
Monday's interview with him. As we discussed, there appear to be some Maxwell phone records.
thanks for
running point on the project we just discussed relating to those records.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
)"
(USANYS)"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Date: Wed, 16 Sep 2020 21:48:56 +0000
Attachments: 2020-09-16_Government_ex_parte_letter_re_sealing_20_Cr_330_(AJN).pdf
Good afternoon,
Pursuant to Judge Nathan's September 15, 2020 memo endorsement order, attached please find a supplemental letter,
which the Government respectfully requests be filed ex parte and under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
From: Nathan NYSD Chambers
Sent: Tuesday, September 15, 2020 2:47 PM
To:
Cc:
>;
(USANYS)
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Good afternoon,
Please find attached a memo endorsement signed by Judge Nathan, which will temporarily remain under seal. Please
confirm receipt.
Respectfully,
Juan Ruiz Toro
Law Clerk to the Hon. Alison J. Nathan
From:
)
Sent: Monday, September 14, 2020 8:00 PM
To: Nathan NYSD Chambers
Cc:
is
(USANYS)
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Good evening,
Attached for Judge Nathan's consideration please find a letter pursuant to Federal Rule of Criminal Procedure 16(d)(1),
which the Government respectfully requests be filed ex parte and under seal.
EFTA00019645

=== Page 2 ===
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
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From:
)"
To:
)"
Subject: Re: MCC Visit Thursday
Date: Thu, 15 Aug 2019 11:25:57 +0000
Should we invite paralegals? Interns?
On Aug 15, 2019, at 6:21 AM,
)
wrote:
I'm not going to spend any more time on this, if LE agents want to come they can deal with any issues that
come for not giving MCC a heads up. But I'm sure it'll be fine.
Begin forwarded message:
From:
Date: August 15, 2019 at 5:57:26 AM EDT
To:
i
Subject: Re: MCC Visit Thursday
Thanks for the heads up. If it's possible to get them before you come, please do.
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
Date: 8/14/19 10:56 PM (GMT-05:00)
To:
i
Subject: Re: MCC Visit Thursday
)" 08/14/2019 22:56
I just found out that additional law enforcement agents will be joining but I don't know how many and who. I
asked. I'm sorry!
On Aug 14, 2019, at 12:49 PM,
)
wrote:
Resending, I got an error last time.
From:
Sent: Wednesday, August 14, 2019 12:41 PM
To:
is
Cc:
Subject: RE: MCC Visit Thursday
EFTA00017788

=== Page 2 ===
Ed O'Callahan - Principal Deputy Attorney General
Geoffrey Berman - US Attorney
From:
Sent: Wednesday, August 14, 2019 12:26 PM
To:
is
Cc:
Subject: RE: MCC Visit Thursday
Hi
Not a problem. I will add them to the list. Do you have everyone's titles?
I will advise the Warden of the request that he accompany us on the tour.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
>>>
)" <
> 8/14/2019 12:17 PM >>>
Two additional people from DOJ will join the visit:
Ed O'Callahan
In addition, Geoff has asked that the new acting warden join the tour. Let me know if you have any questions,
thanks.
From:
Sent: Tuesday, August 13, 2019 4:03 PM
To:
i
)
EFTA00017789

=== Page 3 ===
Cc:
Subject: RE: MCC Visit Thursday
If it is not too much of an imposition, we ask that all visitors come to our front lobby for screening before admission.
Thanks!
>>>
)"
> 8/13/2019 3:58 PM >>>
Yes, thank you. Where should we go?
From:
Sent: Tuesday, August 13, 2019 3:38 PM
To:
i
)
Cc:
Subject: Re: MCC Visit Thursday
Hi
It should not be a problem. Does 10 am work for Mr. Berman and the rest of his staff?
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
>>>
)"
> 8/13/2019 2:05 PM >>>
The list of visitors from our office is below:
Geoffrey Berman
As discussed, we would like to see the 2nd floor pscyh observation and suicide watch area; the 9th floor SHU, and
Epstein's cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal
would escort us, and we will not speak to any of the guards present given the ongoing investigations. Please give
me a call with any questions, and let us know what time and where we should go, and if it would be easier for us to
enter via the 3rd floor bridge.
Thanks,
EFTA00017790

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
Tel:
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=== Page 1 ===
From:
)"
To:
Subject: RE: Korea Bribery Subpoenas
Date: Fri, 10 Jul 2020 16:27:20 +0000
Attachments: 2020.07.08,_subpoena_to_Jacqueline_Hudkins_Attorney_at_Law_(corrected).docx
Thanks so much,
I was actually able to scan my version of
signature the other day. Attached is a subpoena
from another case with that signature included. Would you please insert it into all of these subpoenas for the Korea case?
Couple other corrections:
All of the riders appear to have a typo in the sentence beginning "A list of accounts hold, controlled, or accessible
to the following individual(s) and/or entity(ies)," which should instead read "A list of accounts held, controlled, or
accessible to". Would you please fix that before sending out?
There are a couple instances in which the word "Alaska" is misspelled (it's written "Alaksa" in the riders). Would
you please correct those?
Some of the riders have highlighting in them-would you please remove that?
With those changes, these are good to go out.
Thanks,
From:
Sent: Thursday, July 9, 2020 4:29 PM
To:
Subject: Korea Bribery Subpoenas
Hey
I just took over paralegal duties from
for this case. There were a number of riders that
sent me and
which I have turned into drafts of subpoenas. All of them are attached and in the drafts folder on the shared.
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=== Page 1 ===
From:
To:
Subject: Re: JE estate meeting
Date: Sat, 21 Dec 2019 00:43:40 +0000
Ah, sorry, just saw this.
On Dec 20, 2019, at 5:22 PM,
wrote:
I'm sorry - my colleagues remind me that this is inaccurate, defense counsel returned and/or destroyed
discovery materials, pursuant to the protective order, following Epstein's suicide. So they won't be able to provide
discovery materials. However, I believe they should separately have copies of the search warrant inventories which
were of course provided separate from the protective order; if they don't, please let us know, and again we'll continue
to try to figure out what if any obligations / restrictions we are subject to on the copies of inventory records that we
have. Apologies for the confusion.
From:
Sent: Friday, December 20, 2019 17:17
To:
Cc:
Subject: RE: JE estate meeting
Marc,
We're not yet exactly sure what our ability is to provide to the Trustees what is effectively discovery in a now-defunct
criminal case against Epstein himself; that said, I can convey that we did produce to defense counsel detailed search
warrant returns in connection with the New York property. Perhaps you would be able to obtain those from Epstein's
criminal defense counsel? In particular I believe what you're looking for would be especially at USAO_4381-4445, but
potentially also USAO_2662-4380 (though I note that a handful of those pages were marked as Confidential under a
protective order, as set forth in the discovery letter sent to counsel on July 31, 2019). We will also review the status of
the search warrant return with respect to the island property (and we have not searched the New Mexico property), and
I hope this is useful in the interim.
Separately, I've conveyed your request for a meeting to discuss the possibility of resolving the Government's potential
forfeiture claims, and I haven't yet gotten a response to relay but will let you know as soon as I do (and will also provide
these dates in connection with your request).
thanks,
From:
Sent: Thursday, December 19, 2019 19:09
To:
Cc:
Subject: JE estate meeting
EFTA00019878

=== Page 2 ===
To follow up on our call, can you please send us the search warrant returns/inventories and, if possible, any additional
detail regarding the items that were seized in the two searches of the New York property and the search of the New
Mexico property.
With respect to a next meeting with you and the Chief of the Criminal Division and, of course, any other colleagues you
wish to attend, the following dates in early January would be good for us:
January 3, 6 (before 2:00), 7, 8 (1:00 or later), 9 (after 11:00), or 10
Happy and Healthy New Year from Andy and me.
Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
Fax
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.
EFTA00019879


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=== Page 1 ===
From:
To:
)"
Cc:
(USANYS)"
)"
"
Subject: RE: Items to Reproduce
Date: Fri, 18 Dec 2020 18:02:51 +0000
Attachments: SDNY_GM_02742184.xlsx; DNY_GM_02742185-SDNY_GM_02742186.pdf;
SDNY_GM_02742190.pdf; SDNY_GM_02742191-SDNY_GM_02742236.pdf
SDNY_GM_02742237-SDNY_GM_02742268.pdf;SDNY_GM_02742269-
SDNY_GM_02742302.pdf; 2020.12.18_Maxwell_Discovery_Letter.docx
Of course, and I'm sorry it happened in the first place! Attached please find the cover letter draft (if that's helpful), as well
as the seven re-stamped items. I also added them to the shared and updated our discovery index. Thanks so much! l'll
begin burning a CD for the MDC now.
From:
Sent: Friday, December 18, 2020 12:57 PM
To:
Cc:
(USANYS)
is
is
(USANYS) [Contractor]
Subject: Re: Items to Reproduce
Thanks you so much for catching that, letting us know, and fixing it so quickly,
Really appreciate that. Please just
let me know when the reproductions are ready to go, and I'll email defense counsel and the MDC.
On Dec 18, 2020, at 11:36 AM,
]
wrote:
Hi all,
I was updating the discovery index for Maxwell and unfortunately realized that seven items (two items from the 7th
Production, located here; and all five PDFs from the 8th Production, located here) will have to be reproduced, as their
Bates numbers were slightly incorrect (missing a digit in the middle of the bates number). I can re-stamp and update
them in the shared momentarily - but my apologies that we're just now catching this!
The seven reproduced items will consist of one Excel file and six PDFs, so they'll be small enough to email to defense
counsel and small enough to put on a disc to send to Maxwell at MDC. I can draft a cover letter detailing the reproduced
items and their updated Bates ranges, and since I'm in the office today I can send the disc out to MDC this afternoon.
Thanks so much for your understanding!
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
EFTA00019289

=== Page 2 ===
Cell:
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=== Page 1 ===
From:
)"
To:
Cc:
(NY) (FBI)"
)"
)"
Subject: RE: St Thomas jet center
Date: Tue, 13 Aug 2019 16:26:17 +0000
Hi
Thanks, that probably makes sense. Are you guys back in the city? Let's all check in at some point to talk about next steps.
Thanks.
From:
Sent: Tuesday, August 13, 2019 12:08 PM
To:
)
Cc:
(NY) (FBI)
Subject: Fwd: St Thomas jet center
Would you want to cut a Subpoena to this company for his flight records?
Begin forwarded message:
From:
(NY) (FBI)"
Date: August 13, 2019 at 11:59:18 AST
To:
(NY) (FBI)"
i
Subject: St Thomas jet center
Hey guys,
just wanted me to reach out to you guys, I interviewed the air traffic control guy Pat, and through a couple
phone calls, we believe that St. Thomas Jet Center (340-777-9177, Pat Hatch, employee) dealt with Epstein's
helicopter. I called over there to confirm and they said the company has no comment and will not confirm
anything regarding Epstein. Just wanted you guys to know in the event a subpoena was needed.
Special Agent
FBI-New York
Child Exploitation/Human Trafficking Task Force
Desk:
Cell:
EFTA00019761


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=== Page 1 ===
Event: Accepted: SDNY-ODAG Call (Epstein/Maxwell)
Start Date: 2020-08-19 14:00:00 +0000
End Date: 2020-08-19 14:30:00 +0000
Location
Conf. Id 758788
Class: X-PERSONAL
Comment:
Date Created: 2020-08-18 17:08:11 +0000
Date Modified: 2020-08-18 17:08:11 +0000
Priority: 5
DTSTAMP: 2020-08-18 16:59:08 +0000
Attendee:
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 1 of 11
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 5, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007
Re:
United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in connection with the Court's Order of
March 24, 2021, regarding the defendant's application for an order authorizing a subpoena
pursuant to Rule 17(c) of the Federal Rules of Criminal Procedure for records from Boies Schiller
Flexner LLP ("BSF"). For the reasons set forth herein, the Government respectfully requests that
the Court (1) direct the defendant to provide the Government with a copy of the proposed subpoena
to BSF and notice of all existing and future applications for subpoenas under Rule 17(c) returnable
in advance of trial, and (2) direct that any productions made in response to Rule 17(c) subpoenas
be produced to the opposing party and marked confidential under the protective order.
I.
Background
As the Court is aware, the Government has produced to the defendant more than 2.7 million
pages of discovery pursuant to the Government's various discovery obligations, including Rule
16. The parties are also in discussions about the timing of further productions by the Government,
including material provided pursuant to 18 U.S.C. § 3500 and Giglio material.
EFTA00018236

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 2 of 11
Page 2
Those obligations, and not Rule 17 subpoenas, provide the avenue through which
defendants in criminal cases obtain discovery. As the Supreme Court has explained, "[i]t was not
intended by Rule 16 to give a limited right of discovery, and then by Rule 17 to give a right of
discovery in the broadest terms." Bowman Dairy Co. V. United States, 341 U.S. 214, 220 (1951);
see also United States V. Purin, 486 F.2d 1363, 1368 (2d Cir. 1973) ("A subpoena duces tecum in
a criminal case is not intended as a means of discovery."). Unlike the rules of civil procedure-
permitting the issuance of subpoenas to seek production of documents or materials which, although
themselves not admissible, may lead to admissible evidence-the criminal rules do not authorize
the issuance of such broad pretrial subpoenas under Rule 17. See United States V. Cherry, 876 F.
Supp. 547, 552 (S.D.N.Y. 1995); United States V. Gross, 24 F.R.D. 138, 141 (S.D.N.Y. 1959)
(Rule 17(c) cannot be used "to obtain leads as to the existence of additional documentary evidence
or to seek information relating to the defendant's case. This type of discovery, permissible under
the Federal Rules of Civil Procedure, has not been authorized for criminal trials.").
The purpose of Rule 17(c) is to "expedite the trial by providing a time and place before
trial for the inspection of" specific materials that the parties intend to offer into evidence. See
United States V. Tagliaferro, No. 19 Cr. 472 (PAC), 2021 WL 980004, at *2 (S.D.N.Y. Mar. 16,
2021) (citing Bowman Dairy Co., 341 U.S. at 220 (1951)); see also United States V. Ulbricht, 858
F.3d 71, 109 (2d Cir. 2017) (explaining that the rule "allows parties to subpoena documents and
objects to be introduced at criminal trials"), abrogated on other grounds as recognized by United
States V. Chambers, 751 F. App'x 44, 46 & n.1 (2d Cir. 2018) (summary order). Accordingly,
the Supreme Court has explained that, to require production of materials pursuant to Rule 17(c),
the party seeking production must show that:
(1) that the documents are evidentiary and relevant; (2) that they are
not otherwise procurable reasonably in advance of trial by exercise
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=== Page 3 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 3 of 11
Page 3
of due diligence; (3) that the party cannot properly prepare for trial
without such production and inspection in advance of trial and that
the failure to obtain such inspection may tend unreasonably to delay
the trial; and (4) that the application is made in good faith and is not
intended as a general "fishing expedition."
United States V. Nixon, 418 U.S. 683, 699-700 (1974) (footnote omitted); see United States V.
Skelos, 988 F.3d 645, 661 (2d Cir. 2021) (affirming a decision to quash subpoenas through
application of Nixon); United States V. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *1-*2
(S.D.N.Y. Feb. 12, 2016) (applying Nixon, rather than the "more liberal standard" of United States
V. Tucker, 249 F.R.D. 58 (S.D.N.Y. 2008), to the propriety of a Rule 17(c) subpoena).
The Nixon test is demanding. The defendant must establish that the defense's "application
is made in good faith and is not intended as a general "fishing expedition." Nixon, 418 U.S. at
700; United States V. Yian, No. 94 Cr. 719 (DLC), 1995 WL 614563, at *2 (S.D.N.Y. Oct. 19,
1995) (quashing subpoena that "call[s] for the production of the entire investigative file and is
accurately described as a fishing expedition"); United States V. Cuthbertson, 630 F.2d 139, 144
(3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to
obtain identified evidence rather than a general "fishing expedition' that attempts to use the rule as
a discovery device." (emphasis added)). Indeed, because the Rule poses such a risk of abuse and
misuse, courts are stringent in holding those seeking to obtain documents to Rule 17(c) to their
burden of demonstrating that the documents sought are (1) relevant, (2) admissible, (3) specifically
identified, and (4) not otherwise procurable, and it is "insufficient" for a party to show only that
the subpoenaed documents "are potentially relevant or may be admissible," United States V. RW
Prof'l Leasing Servs. Corp., 228 F.R.D. 158, 162 (E.D.N.Y 2005) (emphasis added). "[A] mere
hope that the documents, if produced, may contain evidence favorable to the defendant's case will
not suffice. Rule 17(c) requires a showing that the materials sought are currently admissible in
EFTA00018238

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 4 of 11
Page 4
evidence; it cannot be used as a device to gain understanding or explanation." United States V.
Rich, No. 83 Cr. 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984) (internal quotation
marks omitted) (emphasis added). Accordingly, subpoenas that call for "any" and "all" records
"do not evince specificity" and "read[] like a discovery request, which is not permitted under Rule
17(c)." Tagliaferro, 2021 WL 980004 at *3; see Pena, 2016 WL 8735699, at *3. And "[g]enerally
the need for evidence to impeach witnesses is insufficient to require its production in advance of
trial." Nixon, 418 U.S. at 701 (citations omitted); see Fed. R. Crim. P. 17(h) ("No party may
subpoena a statement of a witness or of a prospective witness under this rule.").
If a subpoena calls for "personal or confidential information about a victim," the subpoena
may be served "only by court order" following "notice to the victim so that the victim can move
to quash or modify the subpoena or otherwise object." Fed. R. Crim. P. 17(c)(3). After a subpoena
issues, "[t]he court may direct the witness to produce the designated items in court before trial or
before they are to be offered in evidence." Fed. R. Crim. P. 17(c)(1). "When the items arrive, the
court may permit the parties and their attorneys to inspect all or part of them." Id.
II.
The Court Should Direct the Defendant to Provide Notice of Prior and Future
Applications Under Rule 17(c) to the Government
The Government has legitimate and cognizable interests in Rule 17(c) subpoenas issued by
the defense. In particular, courts have routinely found that the Government has standing to move
to quash Rule 17(c) subpoenas that target information about anticipated Government witnesses
"based on the Government's 'interest in preventing any undue lengthening of the trial, any undue
harassment of the witness and his family, and any prejudicial over-emphasis on the witness's
credibility." United States V. Ray, -- F.R.D. --, No. 20 Cr. 110 (LJL), 2020 WL 6939677, at *7
(S.D.N.Y. Nov. 25, 2020) (alterations omitted) (quoting United States V. Giampa, No. 92 Cr. 437
(PKL), 1992 WL 296440, at *1 (S.D.N.Y. Oct. 7, 1992)); see United States V. Bergstein, No. 16
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=== Page 5 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 5 of 11
Page 5
Cr. 746 (PKC), 2017 WL 6887596, at *2-*3 (S.D.N.Y. Dec. 28, 2017) ("Preventing the undue
harassment of a cooperating witness is a legitimate governmental interest giving rise to standing
in this context."); cf. United States V. Nachamie, 91 F. Supp. 2d 552, 558-60 (S.D.N.Y. 2000)
(concluding that the Government failed to establish a legitimate interest where, among other
things, none of the subpoenaed entities had been "publicly identified by the Government as trial
witnesses, or as particularly vulnerable witnesses"). That is particularly true where the subpoena
at issue seeks material that the defendants would be entitled to, if at all, as Giglio or 3500 material
given that the Government has a cognizable interest in "controlling the timing of disclosures as
to" witnesses who are expected to testify at trial, and for whom the Government has various
disclosure obligations. United States V. Cole, No. 19 Cr. 869 (ER), 2021 WL 912425, at *2
(S.D.N.Y. Mar. 10, 2021); see Bergstein, 2017 WL 6887596, at *3. Finally, the Government has
standing to challenge subpoenas that call for its own communications. See United States V. Carton,
17 Cr. 680 (CM), 2018 WL 5818107, at *3 (S.D.N.Y. Oct. 19, 2018) (quashing a subpoena for
communications with the Government).¹
The only way for the Government to vindicate those interests is with notice so that the
Government may, as appropriate, have an opportunity to quash the subpoenas. There is no avenue,
after a subpoena is issued and fulfilled, for the Government to protect its interests in the timing of
disclosures about victims or the disclosure of the Government's own communications. That is
particularly important given that a subpoena recipient may lack sufficient knowledge about the
1 The Government also has standing to challenge a Rule 17(c) subpoena at the request of a victim,
witness or third-party impacted by the subpoena. See Ray, 2020 WL 6939677, at *7 ("Courts have
acknowledged that the Government has standing to challenge Rule 17(c) subpoenas directed to a
non-party when the non-party authorizes the Government to assert his or her right by request or by
indicating its joinder in a motion to quash." (internal quotation marks and alteration omitted)).
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Page 6
case or motivation to move to quash an otherwise improper subpoena. 2 Accordingly, the
Government respectfully requests notice of all subpoenas with pretrial return dates issued or sought
to be issued under Rule 17(c). 3
While, as the Court noted in its Order, Rule 17(c) subpoenas are frequently issued ex parte
in this district, the issue is rarely litigated. See, e.g., United States V. States V. Wey, 252 F. Supp. 3d
237, 243 (S.D.N.Y. 2017) (noting, without extended discussion, that subpoena had issued upon ex
parte application); United States V. Earls, No. 03 Cr.0364 (NRB), 2004 WL 350725, at *6 (S.D.N.Y.
Feb. 25, 2004) (noting that the defendant may seek subpoenas ex parte). When courts have considered
the issue, however, many have directed that the parties should give each other notice of Rule 17(c)
subpoenas unless a party can justify proceeding ex parte. See United States V. Skelos, No. 15 Cr.
317 (KMW), 2018 WL 2254538, at *8 (S.D.N.Y. May 17, 2018) (explaining that courts have
permitted ex parte requests "where a reason existed for doing so," and requiring notice "[t]o further
reduce the risk that trial will be delayed, unless a party has a compelling reason for proceeding ex
parte with a subpoena request"), aff' 988 F.3d 645 (2d Cir. 2021); United States V. St. Lawrence,
16 Cr. 259 (CS), Dkt. No. 66 at 6 (S.D.N.Y. Dec. 22, 2016) (requiring motions for Rule 17(c)
subpoenas and permitting ex parte applications "if the movant can articulate a reason why it should
be"); United States V. Boyle, No. 08 Cr. 523 (CM), 2009 WL 484436, at *3 (S.D.N.Y. Feb. 24,
2009) (requiring noticed motions for Rule 17(c) subpoenas to "assur[e] that such subpoenas are
not abused or used for impermissible discovery," and permitting ex parte applications "where a
2 For example, a financial institution may lack sufficient knowledge about the case or motivation
to expend the resources to move to quash what appears to be a routine subpoena that broadly seeks
financial records for a Government cooperator or lay witness to be used for impeachment purposes,
notwithstanding the fact that such a subpoena may run afoul of the Nixon standard.
3 The Government is not seeking notice of subpoenas returnable at trial.
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=== Page 7 ===
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Page 7
party can demonstrate" a basis (emphasis omitted)); United States V. Weisman, 01 Cr. 529 (BSJ),
2002 WL 1467845, at *1 (S.D.N.Y. July 8, 2002) (similar); see also United States V. Fox, 275 F.
Supp. 2d 1006, 1012 & n.7 (D. Neb. 2003) (surveying the caselaw and adopting the "majority
view" that Rule 17(c) "does not ordinarily permit the use of ex parte applications by the
government or the defense for subpoenas seeking pretrial production of documents unless the sole
purpose of seeking the documents is for use at trial," and even then, only if "there is a good trial-
related reason" and generally requiring production in the presence of the opposing party); 2 Wright
& Miller, Fed. Prac. & Procedure $ 275 (4th ed.) ("It has been held, however, that in limited
circumstances, both the government and a defendant may make an ex parte application for a pre-
trial subpoena duces tecum" (emphasis added)). But see Ray, 2020 WL 6939677 at *8 ("Courts
in this District have long followed the practice of permitting both the defense and the Government
to submit ex parte applications for Rule 17(c) subpoenas."); United States V. Reyes, 162 F.R.D.
468, 470 (S.D.N.Y. 1995) (permitting ex parte applications because a party must "detail its trial
strategy or witness list in order to convince a court that the subpoena satisfies the Nixon
standards"). Notice of Rule 17(c) subpoenas is similarly appropriate in this case to prevent abuse
and address objections expediently. And such a requirement is consistent with the plain language
of Rule 17: while Rule 17(b) expressly provides for an ex parte procedure for indigent defendants
seeking to subpoena a witness for trial, it makes no such provision for an application for the
production of documents and objects pursuant to Rule 17(c).⁴
4 In Ray, the Court concluded that Rule 17(c) is simply an extension of Rules 17(a) and (b)'s
provisions of subpoenas to witnesses, which may issue without notice. See 2020 WL 6939677, at
*8 (quoting United States V. Florack, 838 F. Supp. 77, 79 (W.D.N.Y. 1993)). However, Rule 17(c)
subpoenas for records are quite unlike subpoenas for trial testimony: they can be made returnable
before trial, and Rule 17(c)'s text provides that materials obtained pursuant to such a subpoena
may be returnable to the Court, which may in turn "permit the parties and their attorneys to inspect
all or part of them," and subjects the subpoenas to motions to quash. Fed. R. Crim. P. 17(c)(1)-(2)
EFTA00018242

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 8 of 11
Page 8
Moreover, as the information currently available to the Government about the BSF
subpoena makes plain, the Government's concerns are well founded. Indeed, the defendant has
already sought issuance of a subpoena that appears to directly implicate the Government's interests
by expressly and improperly seeking broad categories of victim information and communications
with the Government. While the Government has not seen the subpoena to BSF, it also appears
that the subpoena constitutes a fishing expedition for potential impeachment material, which
plainly runs afoul of the Nixon test. (Letter from BSF to the Court at 2, Dkt. No. 191). 5 Insofar
as the defendant is attempting to engage in such an improper expedition in this case-or even if
the defendant is merely pushing the limits of a Rule 17 subpoena-the Government respectfully
submits that it should be afforded the opportunity to bring its concerns to the Court's attention.
The Government recognizes that some information, such as portions of a defendant's
explanation for why a particular request in a particular subpoena meets the Nixon standard, may
reveal critical defense strategy meriting ex parte consideration by the Court. But the Government
respectfully submits that interest can be served through specific defense requests tailored to the
particular redaction or application at issue, rather than a default whereby the defendant is permitted
to proceed entirely ex parte in seeking documents and materials pursuant to Rule 17(c).
(emphasis added); see United States V. Reyes, 162 F.R.D. 468, 470 (S.D.N.Y. 1995) ("Rules 17(a)
and 17(b), which govern the issuance of subpoenas returnable at trial, also do not provide guidance
as to the proper procedure for obtaining a pretrial subpoena duces tecum."). These procedures are,
at a bare minimum, in tension with proceeding ex parte or under the rules that govern subpoenas
for trial testimony.
5 The Government has also not seen any response filing by the defendant, which per the Court's
March 24, 2021 Order was to be filed on or before April 2, 2021. To the extent the defendant did
file such a response, it was neither docketed nor provided to the Government, and as such, the
Government is unable to address herein any arguments made by the defendant about the BSF
subpoena.
EFTA00018243

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 9 of 11
Page 9
III.
Any Records Obtained Pursuant to a Rule 17(c) Subpoena Should Be Marked
Confidential Under the Protective Order and Produced to the Opposing Party
Additionally, and to the extent the defendant has issued or will issue other subpoenas ex
parte pursuant to Rule 17(c), the responsive records should be produced to the Government and
marked confidential pursuant to the protective order. See Fed. R. Crim. P. 17(c)(1).
First, materials gathered pursuant to a Rule 17(c) subpoena by either party should be
promptly made available to their adversary. As noted above, the text of Rule 17(c) plainly provides
that materials obtained pursuant to a subpoena may be returned to the Court which "may permit
the parties and their attorneys to inspect all or part of them." Fed. R. Crim. P. 17(c)(1). Nowhere
does the Rule provide for one party's ability to use a subpoena to secretively gather material in
advance of trial, nor does it include a categorical exception due to concerns about defense or trial
strategy. Indeed, because the purpose of Rule 17 is to obtain evidence for use at trial, and not to
investigate for evidence or obtain impeachment material, disclosure of the fruits of a Rule 17(c)
subpoena fits neatly with Rule 16's reciprocal obligations for disclosure of evidence that the
defendant intends to introduce in her case-in-chief. See Fed. R. Crim. P. 16(b)(1)(A); United States
V. St. Lawrence, 16 Cr. 259 (CS), Dkt. No. 66 at 6 (S.D.N.Y. Dec. 22, 2016) ("It seems to the Court
that because Rule 17(c) subpoenas are intended to obtain specific materials that the party expects
to offer into evidence, Rule 16 would oblige the party to make the materials available to the other
side anyway.").6
By contrast, to the extent the defendant has improperly obtained information through a
Rule 17(c) subpoena, the Government should have the opportunity to move to preclude its use at
trial. In order to permit such a motion to be made in a timely manner-and so as to avoid the
6 To the extent the Government makes use of Rule 17(c) subpoenas, it similarly will promptly
produce all material received to the defendant.
EFTA00018244

=== Page 10 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 10 of 11
Page 10
unnecessary delay and disruption that will occur if the Government only learns of the existence of
such material during trial-the Government seeks disclosure of any records obtained in response
to such a subpoena. At a minimum, the Court should order production of subpoena returns directly
to the Court, so it may screen out irrelevant or improper information and determine whether any
materials should be made available to the Government as well as the defendant.
Second, the Court should direct that any material obtained pursuant to a Rule 17 subpoena
be marked confidential and subject to the protective order. As noted above, the BSF subpoena
appears to call for a substantial amount of sensitive personal information about victims. For
instance, according to the letter from BSF, the subpoena to BSF requests the "original, complete
copy" of a victim's diary. (Letter from BSF to the Court at 5, Dkt. No. 191). To the extent the
defendant has obtained or will obtain sensitive information about victims or witnesses, it should
be treated as "confidential" under the protective order much like other such information in this
case.
EFTA00018245

=== Page 11 ===
Case 1:20-cr-00330-AJN Document 195 Filed 04/05/21 Page 11 of 11
Page 11
IV. Conclusion
The Government respectfully requests that the Court order the defendant to provide notice
to the Government of pending and future applications for Rule 17(c) subpoenas returnable in
advance of trial, and for the Court to order that any records obtained in response to Rule 17(c)
subpoenas be treated as confidential under the protective order and disclosed to the Government.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
by:
/s/
Assistant United States Attorneys
cc:
Counsel of Record (by ECF)
EFTA00018246


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=== Page 1 ===
From:
To:
"
Subject: RE: Epstein victim call
Date: Wed, 17 Mar 2021 18:22:27 +0000
Thanks for letting us know. I just pinged the agents for a third time about this.
From:
Sent: Wednesday, March 17, 2021 2:14 PM
To:
is
Cc:
Subject: Re: Epstein victim call
Hey sorry but can you guys have an agent reach out to her? She called me again this morning. I'm trying to avoid having
her bother any of you directly but she's very insistent about having information. Thanks.
Sent from my iPhone
On Mar 10, 2021, at 14:12,
wrote:
Just FYI, got another call from Ms.
this afternoon, looking for a follow-up. We did not discuss anything
substantive, and I said I would pass along that she had called.
From:
)
Sent: Thursday, February 25, 2021 12:46
To:
is
Cc:
Subject: Epstein victim call
Team, I just received a call on my desk line from a woman named
who identified herself as a former
client of
and said she was a former victim of Jeffrey Epstein. I asked if her attorney had been in touch
with either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he had
not been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her cell
phone as
She did not provide any substantive information on the call, and I did not ask for any. I advised
that someone would follow up with her, hopefully in the next week or so. The call lasted less than three minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine Epstein
victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing to speak
with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which we
couldn't find online). I believe the last communication we had with him was the attached.
thanks,
EFTA00019017

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00019018


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=== Page 1 ===
ORIGINAL
AO Doc#2 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.
See Attachment A
)
)
9MAG
)
6571
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):
Title 18, United States Code, Sections 371 and 1591
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
July 21, 2019
(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).
luntil, the facts justifying, the later specific date of
Date and time issued: 7-7-19 11:33P.M.
Judge S signature
City and state: New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00020130

=== 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
EFTA00020131

=== Page 3 ===
ATTACHMENT A
I. The Subject Devices to Be Searched
The Subject Devices are particularly described as compact discs stored in containers
marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at 9
East 71st Street, New York, New York, on or about July 7, 2019.
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain 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.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
2.
Any photographs of victims or potential victims of the Subject Offenses;
3.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
4.
Motion pictures, films, videos, and other recordings of visual or written depictions
of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. $ 2256(2);
5.
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;
6.
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).
B. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the ESI contained therein for information
responsive to the warrant.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
2017.08.02
EFTA00020132

=== Page 4 ===
surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
"scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation6; and
reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
II.A of this Attachment. However, law enforcement personnel are authorized to conduct a
complete review of all the ESI from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant.
6 Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
2
2017.08.02
EFTA00020133


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: WSJ
Date: Wed, 14 Aug 2019 18:19:35 +0000
Will report that federal prosecutors and investigators are probing whether the two staffers guarding Jeffrey Epstein's unit
the night of his death falsified records that logged how often they were checking on him.
If the staffers are found to have falsified records, they could face criminal charges in the Southern District of New York.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00017786


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=== Page 1 ===
From:
To:
Cc:
)"
Subject: Hotel and Conference room - West Palm Beach on November 4
Date: Tue, 22 Oct 2019 19:11:27 +0000
Importance: High
Attachments: Florida_Tax_Exemption_Certificate.pdf
Hi,
Please see
or
re: the conference room.
Please be sure that your legal asst. creates/submits a travel authorization in E2 for
to officially fund & approve.
Be sure that the hotel does not bill you for the room taxes
Thanks
Traveler,
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_ layouts/15/WopilFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%20Library/TravelStateTaxExemption.pdf&action-default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
Tyrrell for approval.
Please email me a copy of your CWT air / rail e-ticket email & or hotel reservation confirmation
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
EFTA00019713

=== Page 2 ===
From:
Sent: Tuesday, October 22, 2019 2:03 PM
To:
Cc:
is
in
is
Subject: RE: travel approval request
Thanks very much.
From:
Sent: Tuesday, October 22, 2019 14:00
To:
Cc:
is
is
is
Subject: RE: travel approval request
Approved for both and the conference room.
From:
Sent: Tuesday, October 22, 2019 1:55 PM
To:
Cc:
is
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
EFTA00019714

=== Page 3 ===
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
EFTA00019715

=== Page 4 ===
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00019716


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
)"
)"
(USANYS)
[Contractor]"
(USANYS)"
Subject: Re: Epstein PR Final review
Date: Mon, 08 Jul 2019 14:25:01 +0000
Importance: Normal
Just spoke to him - he is planning to use the 800-CALL-FBI number.
Sent from my iPhone
On Jul 8, 2019, at 10:23 AM,
(USANYS)
wrote:
Good with me. I believe we are using FBI line but you should confirm that with
From:
(USANYS)
Sent: Monday, July 08, 2019 10:17 AM
To:
(USANYS)
i
(USANYS)
V.
(USANYS)
is
(USANYS)
is
(USANYS)
is
)
is
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Any other edits? Or are we good to finalize the release?
From:
,
(USANYS)
Sent: Monday, July 8, 2019 9:55 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
)
is
)
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Also in
quote: Are we trying to say no matter where the incident took place?
FBI Assistant Director
said: "We are asking anyone who may have been
victimized by Jeffery 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,
EFTA00018153

=== Page 2 ===
or whatever age you were then, no matter the incident that 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."
From:
(USANYS)
Sent: Monday, July 8, 2019 9:39 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
i
(USANYS)
i
is
)
>;
>
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: Epstein PR Final review
Importance: High
Attached is the final PR for review. Please note that
quote includes the number to call, so we need to
finalize that as soon as possible. Thanks.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Email:
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1 of 5
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 13, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in opposition to the defendant's letter of
August 10, 2020 (the "Defense Letter" or "Def. Ltr."), requesting that the Court order the
Government to disclose the names of certain Government witnesses 11 months prior to trial, and
requesting that the Court intervene in the protocols and individualized inmate determinations of
the Bureau of Prisons. Both applications should be denied.
A. The Defendant's Demand That the Government Name Certain Trial Witnesses
For the third time in as many weeks, the defendant and her counsel have applied to the
Court for relief that is premature, meritless, or both. See Order dated July 23, 2020 (Dkt. 28)
(denying the defendant's request that the Court enter an order prohibiting the Government and
attorneys for non-parties from making extrajudicial statements "concerning this case"); Order
dated July 30, 2020 (Dkt. 37) (denying the defendant's application for a protective order that would
allow the defense to publicly name and identify victims). In the defendant's most recent
application, she asks the Court to order that the Government disclose a partial witness list, in the
form of identifying certain victims referenced in the Superseding Indictment (the "Indictment"),
fully 11 months prior to trial. This request is at best premature given that the production of
discovery, on the schedule agreed to by the defendant, has just begun. Moreover, the parties have
had no discussions about-let alone asked the Court to set-a schedule for pretrial disclosures,
including for witness lists and 3500 material.
In the first instance, the defendant complains about the status of discovery production,
arguing that "almost six weeks since" the arrest of the defendant, the Government is "just now
beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would
begin as soon as the Court entered a protective order." Def. Ltr. at 2. The suggestion that the
Government somehow delayed that initial production is nonsense. As the Court is aware, the
EFTA00017832

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 2
protective order was docketed on Friday, July 31, 2020¹-the timing of which was principally the
result of the defendant's own refusal to agree to the terms of the proposed protective order. The
Government then promptly produced an initial discovery production totaling more than 12,000
pages the following Wednesday, August 5, 2020. Additionally, the Government continues to
produce discovery and earlier today made a second production, as the Government advised defense
counsel last week it intended to do, totaling more than 150,000 pages, principally consisting of
financial records.² Although the Government expects to continue to produce a large amount of
electronic discovery, the two productions already made constitute the vast majority of initial
discovery, including search warrant applications and subpoena returns, which the Government has
now produced more than a week in advance of its deadline of August 21, 2020, and
approximately 11 months prior to trial.
In sum, the Government has acted expeditiously in meeting its initial discovery obligations,
providing more than 165,000 pages of discovery materials in less than two weeks following the
entry of the protective order-all of which was accompanied by detailed indices describing the
general topics and sources of the materials.
Against this backdrop, the Defense Letter claims that over the course of just five days,
defense counsel determined, having "expeditiously reviewed [the discovery] for high level
content," Def. Ltr. at 2, that they cannot possibly investigate the charges against their client based
on the materials provided thus far, and asking the Court to order the Government to provide the
defendant with a partial witness list. That request should be denied.
Tellingly, the defendant cites no authority that requires the relief requested at this stage in
the litigation-i.e., prior to the completion of discovery and approximately 11 months before
trial-nor is the Government aware of any. For example, in the lead case cited by defense counsel,
United States V. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged
the ability of district courts to compel disclosure of the identity of government witnesses, the
Second Circuit reversed for abuse of discretion the district court's decision to do so in that case
because the defendant there, as here, had made "only an abstract, conclusory claim that such
disclosure was necessary to its proper preparation for trial." Id. at 301-02. In United States V.
Rueb, 00 Cr. 091 (RWS), 2001 WL 96177, at *8 (S.D.N.Y. Feb. 5, 2001), while the Court ordered
the Government to provide the defendant with its witness list, it did so one month before trial,
following the completion of discovery production and in the context of pretrial motions. Those
circumstances plainly are not present here. Finally, in United States V. Warme, a Western District
of New York opinion from 2009 that has never been cited by another court, although the Court
1 The Defense Letter states that the protective order was "entered" by the Court on July 30, 2020.
While that is the date the protective order was signed by the Court, it was posted to the docket on
July 31, 2020.
2 The Government's most recent discovery transmittal letter also included the months and years of
birth of the three victims identified in the Indictment, to enable the defendant to evaluate whether
she will make any motions or legal arguments-more than four months in advance of the deadline
for any such motion-relating to the ages of the victims.
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Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 3 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 3
ordered disclosure of a certain victim identity shortly after the indictment, the Court noted that the
Government had already confirmed to the defendant the identities of three of the four relevant
victims, and that a fourth victim, whose identity was at issue, was the subject of a charge that failed
to identify the date of her alleged rape or any prior encounters between the victim and the
defendant. 2009 WL 427111, at *2. None of those facts are present here-by contrast, here, the
Indictment particularly describes relevant time periods and events, including referring to the
defendant's conversations with victims, interactions with victims, and specific relevant locations.
To the extent the defendant is arguing that she cannot identify the nature of the charges
against her, the proper vehicle for such an argument is a motion for a bill of particulars. Any such
motion can be made in December with all other motions and following the completion of
discovery. While the Government anticipates opposing such a motion as baseless on the facts of
this case, the Government respectfully submits that in any event such a motion could not be
meaningfully evaluated at this stage, prior to the completion of discovery. See United States V.
Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a
motion for a bill of particulars that sought, among other things, the "alleged victim and noting that
"[a] bill of particulars is not required unless the charges of the indictment are so general that they
do not advise the defendant of the specific acts of which he is accused. The government can also
discharge its obligation to disclose this information by other means, such as by presenting evidence
in discovery.
A bill of particulars is not meant to provide the details of the government's
evidence, or to be used as an investigative tool.") (emphasis added, quotations and citations
omitted); see also United States V. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489, at *7
(S.D.N.Y. Dec. 3, 2013) (denying a motion for a bill of particulars and noting that such motions
are not "a general investigative tool, a discovery device or a means to compel the government to
disclose evidence or witnesses to be offered prior to trial") (emphasis added) (quotations and
citation omitted); cf. United States V. Sindone, 01 Cr. 517 (MBM), 2002 WL 48604, at *2
(S.D.N.Y. Jan. 14, 2002) (denying a motion for a bill of particulars to identify "the unnamed
alleged victim(s)" but instructing the government to disclose the name of any victim it did not
intend to call as a witness at trial by 14 days prior to the start of trial).
Alternatively, to the extent defense counsel is unable to assess or comprehend the discovery
produced by the Government, the Government is more than willing to discuss with the defense
3 Defense counsel's invocation of the protective order in support of its argument, Def. Ltr. at 1, 3,
should be of little comfort. The Government is deeply concerned by the recent actions of the
defendant's counsel who represent her in both this criminal matter as well as in certain civil
matters, and who in a recent public filing in a civil case referred to their receipt of sealed materials
in discovery in this case. In particular, the defendant's counsel publicly claimed in a civil filing
that they purportedly had received "critical new information" from the criminal case that it could
not disclose "because it is subject to a protective order in the Criminal Action," and further noting
publicly a desire to seek modification of the protective order in this case to use such materials in
the civil case, which the protective order expressly precludes. See Giuffre V. Ghislaine Maxwell,
No. 15 Civ. 7433 (LAP) (Dkt. 1100). Moreover, even assuming the defendant intends to
scrupulously adhere to the terms of the protective order, that would not change the relevant legal
standards, which weigh heavily against granting the requested relief.
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Honorable Alison J. Nathan
August 13, 2020
Page 4
any such issues as the discovery process continues. To date, the defendant has yet to ask the
Government a single substantive question about the discovery. The Government is also prepared
to engage in good faith discussions with the defense about an appropriate schedule for disclosure
of 3500 material, exhibit lists, and witness lists, all of which the Government expects to produce
reasonably in advance of the trial date in July 2021 to permit the defense to investigate witnesses.
But particularly given the nature of the charges, the Government's strong desire to protect the
privacy of the alleged victims, and the lack of any legal precedent for the defendant's request, the
Government respectfully submits that at the present time-eleven months prior to trial, nearly
three months prior to the discovery deadline, and more than four months prior to the pretrial
motions deadline-there is no basis for the defendant to demand the Government disclose the
identity of its witnesses.
B. The Defendant's Request that the Court Dictate the Conditions of Her Confinement
The defendant's requests with respect to the conditions of her confinement at the
Metropolitan Detention Center ("MDC") are similarly premature and unavailing, and her request
that the Court dictate the terms of her confinement to the Bureau of Prisons ("BOP") should also
be denied.4
As an initial matter, the defendant's argument that she is being treated "worse" than other
inmates is incorrect. There is no merit to her complaints about being monitored by staff, as it is
entirely appropriate for BOP to carefully monitor any inmate, particularly a new inmate who has
never before been incarcerated and who faces the strong likelihood of serving many years in prison.
Additionally, like all inmates, the defendant may be subject to observation or searches of her
person or space as appropriate.⁵ It is otherwise entirely unclear what specific "privileges given to
other pretrial detainees" the defendant believes she is being denied.
More generally, the defendant, like all pretrial inmates, is subject to an individualized
assessment by the BOP with respect to his or her placement in a facility. Here, for reasons
including safety, security, and the orderly functioning of the facility, BOP has made the
determination that, at present, the defendant should not be fully integrated into the dorm-style
accommodations of the general population. The Government understands from BOP that it will
4 Once again, defense counsel has rushed to seek Court intervention on issues they have made little
or no meaningful effort to address with the Government or, in this case, the BOP. The Government
learned of the defendant's specific objections to her conditions of incarceration for the first time
from the Defense Letter, and has since conferred with BOP to understand and to address the issues
as appropriate. Moreover, as noted below, the defendant filed the instant challenge to the BOP's
plan to permit her time to review discovery before the BOP had a chance to implement (and
ultimately modify) that plan.
5 Defense counsel claims that prison staff "constantly observe" the defendant "including her phone
conversations with defense counsel." This is misleading. As with all inmates, the defendant is
able to speak to her counsel behind a closed door, in an area that is visible-but not audible-to
MDC staff. Among other reasons, this is so MDC staff can ensure that inmates do not complete
calls with their counsel and then call other individuals on a non-recorded line.
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=== Page 5 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 5 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 5
continue to evaluate where the defendant should be housed within the facility and that the
defendant will be placed into the general population if and when BOP is assured that such
placement would not pose a threat to the orderly operation of the institution. The defendant
identifies no basis for the Court to disturb that determination by the BOP, particularly given that,
as detailed below, her housing assignment will not negatively affect her ability to review discovery
in this case.
Regarding the defendant's request in connection with access to discovery, the Government
understands from BOP that the defendant had not even yet received her copy of the Government's
first discovery production at the time the Defense Letter was filed-she received the materials on
Tuesday, August 11. While it is correct that BOP's initial plan was to provide three hours per day
of access to the discovery-the same access that is granted to every other pretrial inmate, including
those with trial dates scheduled for far earlier than July 2021-as of earlier this week, and given
the volume of expected discovery, BOP informed the defendant that she will have the opportunity
to access to her discovery from 7:00 a.m. to 8:00 p.m. every day of the week. Although this
arrangement will be subject to continued evaluation on an ongoing and individualized basis, and
is subject to ordinary considerations of prison operations, BOP intends to provide that access on
an ongoing basis to the extent it remains reasonably practicable to do so. Accordingly, this
application should be denied as moot.
C. Conclusion
For the reasons set forth above, the defendants' requests, as set forth in the Defense Letter,
should be denied.
Respectfully submitted,
AUDREY STRAUSS
A Acting United States Attorney
By:
/
/
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2415
Cc:
All counsel of record, via ECF
EFTA00017836


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=== Page 1 ===
From:
To:
Cc:
Subject: [EXTERNAL] U.S. V. Maxwell, S2 20 Cr. 330 (AJN) - Letter re Proposed Limiting
Instructions
Date: Mon, 22 Nov 2021 05:41:44 +0000
Attachments: 2021.11.22_Letter_to_Judge_Nathan_re_Limiting_Instructions.PDF
Inline-Images: image001.gif; image002.gif
Dear Chambers -
With apologies for the delay, attached please find the defendant's letter regarding the proposed limiting instructions in
the Court's Opinion and Order, dated November 19, 2021. The defense submits this letter temporarily under seal.
Regards,
COHEN & GRESSER LLP
800 Third Avenue
New York NY 10022
|
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00019404


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
)"
Subject: FW: French Judicial Police
Date: Thu, 19 Dec 2019 12:45:37 +0000
Attachments: 20191211
- - Incoming.pdf
Per our policy of passing along any civilian information related to Epstein, please see the attached correspondence.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
(CRM)
Sent: Thursday, December 19, 2019 2:01 AM
To:
)
Cc:
is
)
Subject: RE: French Judicial Police
:
Good morning. I've reached out to the investigator.
I also spoke again with the Paris prosecutor's office. Looks like they are going to send us an MLAT request. I will let you
know when that comes in.
Unrelatedly, OIA received the attached citizen correspondence, which I am forwarding to your attention in case there is
anything here for your office or FBI.
Best,
DOJ Attaché/Magistrat de liaison américain
U.S. Embassy, Paris
EFTA00019876

=== Page 2 ===
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=== Page 1 ===
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
To: Nathan NYSD Chambers
Cc:
)"
)"
"Christian Everdell"
<CEverdell@CohenGresser.com>, Laura Menninger <Imenninger@hmflaw.com>, Jeff
Pagliuca <jpagliuca@hmflaw.com>
Subject: Re: U.S. V. Ghislaine Maxwell 20 Cr. 330 (AJN) submission under seal
Date: Tue, 16 Mar 2021 22:39:19 +0000
Attachments: MAXWELL_REPLY_-_BAIL_3.pdf ATT00001.htm
My apologies- dealing with a computer glitch.
The previous email did not contain the memorandum, now attached.
EFTA00018991


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=== Page 1 ===
From:
To:
Subject: Trump Labor chief Alex Acosta resigns due to Jeffrey Epstein case
Date: Fri, 12 Jul 2019 13:49:57 +0000
Importance: Normal
https://www.cnbc.com/2019/07/12/labor-secretary-alex-acosta-is-resigning-as-pressure-mounts-from-jefrey-
epstein-case.html
Sent from my iPhone
EFTA00018182


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: RE: laptop for MDC
Date: Wed, 28 Oct 2020 18:58:25 +0000
Thanks a bunch. Happy to join the call if that's useful. Sounds like we'll need an okay from MDC before
will put this
in motion.
From:
)
Sent: Wednesday, October 28, 2020 2:53 PM
To:
Cc:
(USANYS)
Subject: Re: laptop for MDC
is no longer at MDC, so
is our only liaison right now. I'll reach out to her.
On Oct 28, 2020, at 2:49 PM,
wrote:
Or
not sure who you think is a better.
From:
Sent: Wednesday, October 28, 2020 2:49 PM
To:
is
(USANYS)
Subject: FW: laptop for MDC
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
EFTA00018625

=== Page 2 ===
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.
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:
)
>;
(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-
EFTA00018626


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Cc:
(USANYS)"
Subject: JPMorgan Kept Jeffrey Epstein as a Client Despite Internal Warnings
Date: Thu, 08 Aug 2019 14:53:15 +0000
Have we gotten anything yet from JPMC? Any indication of why they ended their relationship with him in 2013?
As I'm sure you've seen, NYT has a piece up on the relationship which suggests executives at JPMC overruled compliance
efforts to kick him out back in 2008-09 but the article doesn't suggest any financial misconduct or even red flags in his
JPMC accounts, just the fact of his prior conviction.
https://www.nytimes.com/2019/08/08/business/jeffrey-epstein-jpmorgan.html?
action=click&module=Top%20Stories&pgtype=Homepage
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=== Page 1 ===
From:
To: <
Subject: United States V. Jeffrey Epstein
Date: Sat, 10 Aug 2019 17:57:04 +0000
Attachments: mltC634.pdf
Good afternoon,
Enclosed please find official notification from Warden
regarding Mr. Epstein's passing. As the investigation is
ongoing, we have no further details at this time. We will continue to keep you updated as more information is available.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
EFTA00019952


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=== Page 1 ===
(286$ Division MEGA4 Automated Litigation Support System
Account Request and Approval Form
For (286$ Division Users
To be used for DOJ (286$ Division employees and authorized
0 (*$ FRQMDFVRUVWIIIII
DMRQ
DJ NUMBER: 2442-0129
CASE NAME: US V. Epstein
LEAD (286$ DIVISION ATTORNEY NAME AND PHONE NUMBER:
(286$ CASE MANAGER NAME AND PHONE NUMBER:
iCONECT
<
RELATIVITY
LIST OF SPECIFIC CASES/PROJECTS FOR WHICH ACCESS IS REQUIRED:
US V. Epstein
End User Information:
FULL NAME:
EOUSA SECTION:
POSITION/TITLE:
TELEPHONE NUMBER:
BUILDING/LOCATION:
EMAIL ADDRESS:
APPROVED BY:
Date:
6,*1$785(
I
MEGA4 System Access - EOUSA
Page 1 of 8
EFTA00019520

=== Page 2 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
I. Introduction
The Rules of Behavior (ROB) for General Users pertain to the use, security, and acceptable level of risk
for Department of Justice (DOJ) systems. The rules highlight that taking personal responsibility for the
security of an information system and its data is an essential part of your job. As a user of the DOJ
Information Technology (IT) data and systems, you are the first line of defense in support of DOJ's IT
security.
The intent of the ROB is to acknowledge users' receipt and understanding of applicable IT security
requirements from various Federal and DOJ policies and procedures. These requirements include, but
are not limited to, the Office of Management and Budget (OMB) Circular A-130, OMB M-07-16, OMB
M-05-08, the Privacy Act of 1974, DOJ Order 2640.2 (series), DOJ Order 2740.1 (series), and the DOJ
IT Security Standard.
Who is covered by these rules?
These rules apply to all personnel (government employees and contractors) who perform general non-
privileged duties on DOJ information systems, access or use DOJ information, or provide IT services
to DOJ - hereafter referred to as users. All users are required to review and provide signature or
electronic verification acknowledging compliance with these rules to their respective Component IT
Security representative.
Certain authorized personnel may obtain limited exemptions for specific occurrences when performing
official duties. These individuals must document situations where equipment and software limitations
listed below prevent mission operations. In addition to this ROB, the user shall also agree to and
provide signature or electronic verification acknowledging compliance for the Privileged User ROB.
The system Authorizing Official (AO) will issue an exemption if the accepted risk(s) and justification
is documented and appropriate¹.
What are the penalties for noncompliance?
Non-compliance with requirements will be enforced through sanctions commensurate with the level of
infraction. Actions may include a verbal or written warning, temporary suspension of system access or
permanent revocation, reassignment to other duties, or termination, depending on the severity of the
violation. In addition, activities that lead to or cause disclosure of classified information may result in
criminal prosecution under the U.S. Code, Title 18, Section 798, and other applicable statutes.
Unauthorized browsing or inspection of Federal Taxpayer Information (Internal Revenue Code Sec.
7213A) is punishable with a fine of up to $1,000 and/or up to one year imprisonment. Unauthorized
disclosure of Tax Return information (Internal Revenue Code Sec. 7213) is a felony punishable with a
fine of up to $5,000 and up to five years in prison. In addition to these penalties, any Federal employee
convicted under Sec. 7213 or Sec. 7213A will be dismissed from employment.
I For additional information on mobile device exemptions, please refer to the Department of Justice Mobile Device and Mobile
Application Security Policy Instruction v2 http://dojnet.doj.gov/jmd/irm/itsecurity/documents/FINAL-
DOJ_Mobile_Device_and_Application_Security_Policy_Instruction_v2.pdf.
1
MEGA4 System Access - EOUSA
Revised March 2014
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=== Page 3 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
II. User Responsibilities
A. General
1. Comply with all Federal laws and Department and Component policies and requirements,
including DOJ Orders and Standards. Use DOJ information and information systems for lawful,
official use, and authorized purposes only.
2. Do not generate, download, store, copy, or transmit offensive or inappropriate information
in any medium, to include e-mail messages, documents, images, videos, and sound files.
3. Limit distribution of e-mail to only those with a "need to know."
4. Do not open e-mails from suspicious sources (e.g., people you don't recognize, know, or
normally communicate with) and do not visit untrusted or inappropriate websites (unless
authorized). Only download permissible files from known and reliable sources and use virus-
checking procedures prior to file use.
5. Protect and safeguard all DOJ information, including personally identifiable information
(PII), commensurate with the sensitivity and value of the data at risk. Protect and safeguard
all DOJ information and information systems from unauthorized access, unauthorized or
inadvertent modification, disclosure, damage, destruction, loss, theft, denial of service,
improper sanitization, and improper use.
6. Verify that each computer-readable data extract containing sensitive PII data has been erased
within 90 days of origination or that its use is still required.
7. Upon discovery of a known or suspected security incident, report the incident to your Help Desk,
Incident Response Representative, Justice Security Operations Center, Security Manager, or
Supervisor.
8. Immediately report lost or stolen devices (e.g., laptop, phone, tablet, thumb drive) to your Help
Desk, Incident Response Representative, Justice Security Operations Center, Security Manager,
or Supervisor.
9. Encrypt all DOJ Sensitive but Unclassified (SBU) data on authorized mobile computers, laptops,
tablets, and removable media (e.g., removable hard drives, thumb drives, and DVDs) using
Department-approved solutions unless a waiver or policy exemption exists. For classified
environments, follow the procedures required for those networks for data storage and transport.
All data is considered sensitive unless designated as non-sensitive by the Component
Director/Head/Office Head.
10. Read and understand the DOJ security warning banner that appears prior to logging onto the
system or mobile device.
11. Screen-lock or log off your computer when leaving the work area, and remove your PIV card, if
utilized. Log off when departing for the day.
12. Keep all government-furnished equipment (GFE) mobile devices assigned to you in your
2
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=== Page 4 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
physical presence whenever possible. When it is necessary for you to be away from your GFE,
particularly at a non-secure location, secure all your portable electronic devices and removable
media, preferably out-of-sight (e.g. in a locked container).
13. Do not use Peer-to-Peer (P2P) technology on the Internet, such as Skype, BitTorrent, etc. P2P is
forbidden throughout the Department unless the Department's Chief Information Officer (CIO) or
designee approves a waiver.
14. Do not auto-forward emails from your DOJ email account to your personal email account
(e.g., Gmail, Yahoo, Hotmail).
15. Ensure that individuals have the proper clearance, authorization, and need-to-know before
providing access to any DOJ information.
16. Consent to monitoring and search of any IT equipment that is brought into, networked to, or
removed from DOJ owned, controlled, or leased facilities consistent with employee and
contractor consent obtained through log-on banners and DOJ policies.
17. Properly mark and label classified and sensitive documents, electronic equipment, and media in
accordance with the DOJ Security Program Operating Manual (SPOM) and DOJ Order 2620.7.
18. Adhere to Separation of Duties principles. Understand conflict of interest in responsibilities,
roles, and functions within a system or application (e.g., duties of the System Administrator
and Information System Security Officer (ISSO) should not be combined).
19. Do not change any configurations or settings of the operating system and security-related
software, or circumvent and test the security controls of the system unless authorized.
20. Do not bypass native mobile device operating system controls to gain increased privileges (i.e.,
jailbreaking or rooting the device).
21. Do not use anonymizer sites on the Internet and bypass the Department security mechanisms
designed to protect systems from malicious Internet sites.
B. Classified Systems/Information
22. Do not process classified information on an unclassified system unless authorization is
obtained to support a specific job function.
23. Send classified email only on systems authorized for that purpose and for the highest level of
the classified data involved.
24. When in use, operate IT systems only in those areas or facilities certified for the highest
classification or sensitivity level of the information involved. When not in use, store a
classified computer, hard drive, removable media, etc. in an approved security container or in a
facility approved for open storage.
25. Use classified laptops and similar devices in accordance with the DOJ Removable Media
Requirements for Classified Systems, dated April 25, 2011.
3
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EFTA00019523

=== Page 5 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
C. Passwords
26. Adhere to at least the minimum password requirements for the system on which you are
working.
27. Change the default password upon receipt from system administrator.
28. Do not share account passwords with anyone.
29. Avoid using the same password for multiple accounts.
D. Mobile Computing & Remote Access Users
30. Use mobile GFE (e.g., laptop, tablet, smartphone) for official business and authorized uses.
Mobile GFE is for use by DOJ personnel only (no spouses or relatives) and shall only connect
through an authorized DOJ remote access network when accessing the Internet.
31. Only authorized applications and software for mobile GFE can be downloaded and installed on
DOJ devices, and only from DOJ-authorized sources.
32. The use of Short Message Service (SMS) must be approved by the Authorizing Official. SMS
messages are be limited to non-sensitive information.
33. Only install DOJ-provided removable media, including memory and subscriber identity
module (SIM) cards, on mobile GFE.
34. Only connect to secure wireless networks where possible and take precautionary measures to
prevent the compromise of DOJ data when insecure wireless networks must be used. 2
35. Follow these guidelines unless explicitly authorized by the Authorizing Official to do
otherwise:
a. Do not connect non-DOJ mobile devices and/or accessories to DOJ networks. This includes
mobile phones, tablets, laptops, Bluetooth devices, and other devices requiring both wired
and wireless communication access.
b. Do not enable mobile device tethering via Bluetooth, Universal Serial Bus (USB), or Wi-Fi
hotspots on mobile GFE.
c. Do not access non-Government cloud-based services-such as DropBox and iCloud-from
mobile GFE.
d. Do not connect mobile GFE to non-DOJ information systems, to include personal
computers.
E. Virtual Conferencing
36. Hosts and presenters must provide participants with advance notice if the virtual conference
session is being recorded.
2 For additional information, please refer to the Department of Justice Secure Use of Wireless Networks FAQ at
http://dojnet.doj.gov/jmd/irm/itsecurity/ises_team.php.
4
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EFTA00019524

=== Page 6 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
37. Do not access a virtual conference presentation using an account with elevated privileges.
38. Limit presentation information to only that which is authorized for dissemination.
39. Delete all DOJ information on a provider's web site immediately upon the end of a virtual
conference.
40. Do not install any agents or other software designed to enhance or aid in virtual conferencing.
41. Employ strong participant authentication mechanisms (i.e., multi-factor authentication,
creating a pin, unique login credentials, etc.).
42. Enable logging and archiving to provide auditability of participant and host activity, as well as
enable/disable meeting functions (e.g., upload, download, desktop sharing).
F. Hardware
43. Do not add, modify, or remove hardware, or connect unauthorized accessories or
communications connections to DOJ IT resources unless specifically authorized.
44. Do not access the internal components of the computer, or remove the computer or its hard
drive from DOJ facilities unless specifically authorized.
45. Wipe all devices prior to reissue. There is no expectation of maintaining any personal
information, data, or applications on these devices.
G. Software
46. Do not copy or distribute intellectual property - including music, software, documentation,
and other copyrighted materials - without permission or license from the copyright owner.
Use DOJ-licensed and authorized software only.
47. Do not install or update any software unless specifically authorized.
48. Do not attempt to access any electronic audit trails that may exist on the computer unless
specifically authorized.
H. Remote Web Access
49. Follow your organization's telework guidelines when working remotely and/or accessing DOJ
information remotely.
50. Ensure the confidentiality of government information when using remote web access (e.g.,
OWA) from a non-GFE client (public or private). This includes the following:
a. When downloading attachments to registered non-GFE private computers, immediately
remove any extraneous attachments, encrypt them locally, or transfer them to an approved
encrypted USB drive.
b. Delete attachments when finished on registered non-GFE private computers.
c. Do not download attachments on unregistered non-GFE public computers.
5
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EFTA00019525

=== Page 7 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
51. Do not print emails in public areas and with public non-GFE printers. Users may print with
non-GFE private printers at home. Users will be held responsible for the compromise of
Government information through negligence or a willful act.
52. Maintain a reasonable security posture (i.e., updated antivirus, local firewall, updated os and
software patch levels) on registered non-GFE private computers used for remote access.
I. Traveling Users
53. The Component Mobile Computing Operations Manager, or equivalent, shall notify the JSOC,
or an equivalent authorized SOC in advance, if you intend to travel to a foreign country with a
DOJ laptop that will accompany you during any portion of travel with the intended dates and
location(s) of travel. For travel to countries designated as high-risk counter-intelligence, the
use of mobile devices must be approved by the DOJ CISO prior to travel. Requests are
processed via email to both the DOJ ITSS Director and the DOJ ITSS Deputy Director.
54. Minimize the information on your IT system to what is required to perform a particular
mission while travelling and destroy copies of sensitive data when no longer needed.
55. Shut down IT devices when not in use or no longer needed. If the IT device is needed but not
the associated network capability, turn off/disable the network/wireless network functionality.4
56. Assume all communications (including cellular services) are being intercepted and read when
on travel in a foreign country.
57. Keep your remote access token separate from the laptop/tablet (preferably on you) when
possible.
J. Personally Identifiable Information
58. Safeguard against breaches of information involving PII, which refers to information that can
be used alone or combined with other information that can distinguish or trace an individual's
identity-such as a name, social security number, biometric records, the date and place of
birth, mother's maiden name, etc.
59. Report all breaches of information involving PII to JSOC through your Component's standard
procedures.
3 For additional information on foreign travel requirements, please refer to the Foreign Travel Laptop Use and Foreign Travel
Laptop Use Waiver Request forms (http://dojnet.doj.gov/jmd/irm/itsecurity/jsoc-cyber-defense.php). For additional
information on the use of mobile devices during foreign travel, please refer to the Mobile Device and Mobile Application
Security Policy Instruction http://dojnet.doj.gov/jmd/irm/itsecurity/documents/FINAL-
DOJ_Mobile_Device_and_Application_Security_Policy_Instruction_v2.pdf).
4 For additional information, please refer to the Department of Justice Secure Use of Wireless Networks FAQ at
http://dojnet.doj.gov/jmd/irm/itsecurity/ises_team.php.
6
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Page 7 of 8
EFTA00019526

=== Page 8 ===
Department of Justice
Information Technology (IT) Security
Rules of Behavior (ROB) for General Users
Version 7.0
January 3, 2014
60. Access, maintain, store, or transmit PII that you are given explicit authorization to and ensure
you meet required security controls. 5
61. Disclose PII in accordance with appropriate legal authorities and the Privacy Act of 1974.
62. Dispose of and retain records in accordance with applicable record schedules, National
Archives and Records Administration guidelines and Department Policies. 6
63. Do not perform unauthorized querying, review, inspection, or disclosure of Federal Taxpayer
Information. 7 (See Internal Revenue Code Sec. 7213 and 7213A at
http://www.irs.gov/irm/part1/irm_11-003-001.html#d0e176)
I acknowledge receipt and understand my responsibilities as identified above. Additionally, this
acknowledgment accepts my responsibility to ensure the protection of PII that I may handle. I will
comply with the DOJ IT Security ROB for General Users, Version 7.0, dated January 3, 2014.
Signature
Date
Printed Name
Component and Sub-Component
Note: Statement of acknowledgement may be made by signature if the ROB for General Users is
reviewed in hard copy or by email/electronic acknowledgement if reviewed online. All users are
required to review and provide their signature or electronic verification acknowledging compliance
with these rules. Users with privileged accesses and permissions shall also agree to and sign the ROB
for Privileged Users. If you have questions related to this ROB, please contact your Help Desk,
Security Manager, or Supervisor.
The Department has the right, reserved or otherwise, to update the ROB to ensure it remains compliant
with all applicable laws, regulations, and DOJ Standards. Updates to the ROB will be communicated
through the Department's ISES Team Lead and Component Training Coordinators.
5 For additional guidance on PII, please refer to Information Technology Security, DOJ Order 2640.2F
(https://portal.doj.gov/sites/dm/dm/Directives/2640.2F.pdf).
6 For disposal guidance, please refer to Records Management, DOJ Order 2710.11
(https://portal.doj.gov/sites/dm/dm/Directives/2710.11.pdf).
7
For additional information on disclosure of federal taxpayer information, please refer to Internal Revenue Code Sec. 7213 and
7213A (http://www.irs.gov/irm/part1 1/irm_11-003-001.html#d0e176).
7
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EFTA00019527


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: Re: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
Date: Fri, 18 Dec 2020 04:43:14 +0000
Enmbedded: Re:_Jeffrey_Epstein_Estate_Must_Share_Private_Videos_Recorded_At_His_Properties.msg
Sender:
Subject: Re: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
Message-Id: <0176B97D-20EA44A7A-B894-331474261A3F@usa.doj.gov>
To:
Cc:
EFTA00019287


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=== Page 1 ===
From:
)"
To:
USANYS)"
Cc:
(USANYS)"
)"
=
Subject: Epstein database
Date: Wed, 04 Aug 2021 13:51:50 +0000
Hi
While reviewing items in the Epstein search warrant database, I noticed that the subject line of one item was "joint
defense agreement," and so I didn't open it. It's control number USGME00032574, would you mind taking a look please?
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
EFTA00018077


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=== Page 1 ===
From:
To:
Subject: RE: status memo draft
Date: Wed, 06 Mar 2019 17:38:48 +0000
Importance: Normal
302:
During one of the visits Epstein asked her to touch his penis and she told him no.
302:
Epstein wanted
to touch his penis. As she began to reach down toward his penis, Epstein used his hand to direct
her hand toward his penis.
From:
Sent: Wednesday, March 06, 2019 10:17
To:
Subject: RE: status memo draft
Redline attached - let me know if you want to discuss. Thanks!
From:
Sent: Tuesday, March 5, 2019 9:22 PM
To:
Subject: status memo draft
Thoughts? It's a little on the long side (chiefs said ~3 pages was fine) just due to the legal analysis, but they can always cut
that down. Anyway I've never done one of these in particular before so very happy for suggestions. Thanks!
EFTA00019478


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 15:38:05 +0000
Thanks - I have no additional edits.
From:
(USANYS)
Sent: Thursday, December 31, 2020 10:34 AM
To:
(USANYS)
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
I didn't line edit this but I did catch a few typos and had one substantive question.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 5:29 PM
To:
(USANYS)
is
(USANYS)
is
)
in
(USANYS)
is
)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS) 1
is
(USANYS)
^
is
(USANYS)
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Hey everyone: Here's the latest draft of our letter and declaration on this issue. We are still
confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is
also a chance that there's a separate declaration from the MDC; if there is, it should contain the same
substance re: Maxwell that's in the attached draft.
Our response is due tomorrow. I'm generally around later this evening or tomorrow if there's
anything you'd like to discuss.
Thanks very much.
From:
(USANYS)
Sent: Wednesday, December 30, 2020 2:40 PM
To:
(USANYS)
i
(USANYS)
is
(USANYS)
i
(USANYS)
is
)
is
-
V.
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
^
is
(USANYS) 1
>
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
EFTA00018659

=== Page 2 ===
:
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)
is
(USANYS)
i
(USANYS)
>;
is
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Thanks,
Can you keep me posted on what we think will be the substance of the draft declaration when you know
(that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC
and MDC, as well as specific differences in their housing situations?
From:
(USANYS)
Sent: Monday, December 21, 2020 4:35 PM
To:
(USANYS)
i
(USANYS)
i
(USANYS)
is
(USANYS)
is
)
is
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
EFTA00018660

=== Page 3 ===
>;
(USANYS)
is
(USANYS)
is
(USANYS) 1
Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
All:
I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex
trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
general population) cannot be extended to Justin Rivera (detained at the MCC in the general
population).
Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the
MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally
scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had new counsel
appointed, citing an irreconcilable breakdown with his former counsel.
Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires
the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order,
which requires the MCC to make available four hours of videoconferencing each week, in addition to
any telephone or videoconference calls obtained through the Federal Defenders.
At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera
has for videoconferences and electronic discovery review is insufficient for trial preparation, although
defense counsel has stated that they may request more time in the future. However, in a letter last
night and during a court conference this morning (transcript attached), defense counsel cited the
accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and
far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being
treated differently on account of his race, gender and class. Judge Engelmayer stated that the
disparity in access "jumped off the page" and that the optics were "terrible," and asked us to explain
the rationale for the differing treatment. After conferring with
and
before
our conference, we explained our understanding that the disparity comes down to the fact that
Maxwell and Rivera have very different housing situations, with Maxwell's situation being more
amenable to greater access to electronic discovery review and legal visits.
Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera.
Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery
access are as follows:
Accommodation
Maxwell
Rivera
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
EFTA00018661

=== Page 4 ===
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:
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein victim call
Date: Wed, 17 Mar 2021 18:31:38 +0000
Thanks and sorry again for the bother!
Sent from my iPhone
On Mar 17, 2021, at 11:22,
wrote:
Thanks for letting us know. I just pinged the agents for a third time about this.
From:
Sent: Wednesday, March 17, 2021 2:14 PM
To:
is
Cc:
Subject: Re: Epstein victim call
Hey sorry but can you guys have an agent reach out to her? She called me again this morning. I'm trying to avoid having
her bother any of you directly but she's very insistent about having information. Thanks.
Sent from my iPhone
On Mar 10, 2021, at 14:12,
wrote:
Just FYI, got another call from Ms.
this afternoon, looking for a follow-up. We did not discuss anything
substantive, and I said I would pass along that she had called.
From:
Sent: Thursday, February 25, 2021 12:46
To:
is
Cc:
Subject: Epstein victim call
Team, I just received a call on my desk line from a woman named
who identified herself as a former
client of
and said she was a former victim of Jeffrey Epstein. I asked if her attorney had been in touch
with either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he
had not been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her
EFTA00019019

=== Page 2 ===
cell phone as
She did not provide any substantive information on the call, and I did not ask for any. I
advised that someone would follow up with her, hopefully in the next week or so. The call lasted less than three
minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine
Epstein victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing
to speak with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which
we couldn't find online). I believe the last communication we had with him was the attached.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00019020


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From:
To:
Cc:
Subject: Jeffrey Epstein allegedly hired private investigators to stalk his victims - CNN
Date: Fri, 12 Jul 2019 13:21:38 +0000
Importance: Normal
https://www.cnn.com/2019/07/12/us/jeffery-epstein-witness-intimidation/index.html
Sent from my iPhone
EFTA00018706


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From:
To:
Subject: RE: Question
Date: Sat, 30 Jan 2021 04:11:10 +0000
Can I give you a call tomorrow (or Monday) to discuss? Nothing comes to mind in terms of emails, and
was on
Epstein was it first came in, if that's helpful.
From:
Sent: Friday, January 29, 2021 9:16 PM
To:
Subject: RE: Question
Thanks,
Was looking for any emails she may have saved re Epstein.
From:
Sent: Friday, January 29, 2021 8:22 PM
To:
Subject: RE: Question
I don't think that we have all of
trafficking emails, but she saved certain emails relevant to specific topics in the
Coordinator shared drive.
was our predecessor though, so we didn't have a transition conversation with
(although I don't think
saved any emails either). Is there something specific we can help you look for?
From:
Sent: Friday, January 29, 2021 8:05 PM
To:
Subject: Question
Hi,
I hope you both are well! Do you happen to know if
saved her emails on the trafficking share drive? I
have poked around and couldn't find them and
had suggested I check with you on the handoff (I thought you
both stepped into the role when she left, but let me know if I'm wrong).
Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
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=== Page 1 ===
From:
Subject: MCC Press Release
Date: Fri, 15 Nov 2019 19:18:25 +0000
Attachments: MCC_Press_Release_v2.docx
Attached.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00017911


