# docs_fts_content

c1: EFTA00025272
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025272.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Monthly Updates
Date: Fri, 02 Oct 2020 12:53:38 +0000
Attachments: PC_Unit__Short_Form_Update.10.2.20.docx
Left two open for you to fill in. Thanks!
From:
Sent: Wednesday, September 30, 2020 8:48 AM
To:
Cc:
Subject: Monthly Updates
It occurs to me that Friday is the First Friday of October. I've learned from experience that the monthly updates are more
likely to be completed if I remind you. So consider yourselves reminded.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00025272


c1: EFTA00024891
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024891.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
,
)"
Subject: Opening
Date: Thu, 25 Nov 2021 19:59:43 +0000
Attachments: Maxwell_Opening_v7.docx
Happy Thanksgiving!! Attaching a revised draft of the opening for your review. We were thinking of doing a re-moot at
2:30 tomorrow. If you can join, it would be great to have you.
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:
EFTA00024891


c1: EFTA00026863
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026863.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Thu, 13 Feb 2020 15:42:04 +0000
Receipt confirmed.
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: Wednesday, February 12, 2020 at 4:10 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
"
i
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a second subpoena with an accompanying non-disclosure order. Please feel free to
give me a call with any questions.
Thanks,
Maurene
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: Thursday, February 6, 2020 2:46 PM
EFTA00026863

=== Page 2 ===
To:
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Maurene -
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:
)"
"
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,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00026864


c1: EFTA00025165
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025165.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 29, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No.
)
MDC Brooklyn
Metropolitan Detention Center
P.O. Box 329002
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing discovery materials and Government Exhibits pertinent
to Ghislaine Maxwell
(
) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00025165


c1: EFTA00026549
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026549.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE:
- Following up re proffers
Date: Mon, 13 Jan 2020 19:30:14 +0000
Okay, we'll take it off our calendar. Understanding that you provided a preliminary response when we spoke on
Friday, I expect that the final response to that particular account, as well as the issue of Ms.
recollection
(if any) of any other instances more generally in which she observed Jeffrey Epstein engaged in any sexual
activity, or observed other women or girls in sexually-suggestive circumstances (nude or partially nude in the
presence of Epstein, for example, or in connection with massages), other than what you and/or she has already
discussed, is of particular importance and relevance in our and our supervisors' consideration, and we will
immediately incorporate any such response into our ongoing discussions and briefings with them whenever we
receive it.
thanks again,
Original Message
From:
Sent: Monday, January 13, 2020 14:25
To:
Cc:
Subject: RE:
- Following up re proffers
Probably makes sense to do it another time. I'll get back to you. Thanks.
Original Message
From:
Sent: Monday, January 13, 2020 1:38 PM
To:
Cc:
Subject: RE:
- Following up re proffers
-- separately, we still have time blocked off tomorrow at 2:30 for a call. Does it make sense to talk then
EFTA00026549

=== Page 2 ===
so we can get the response to the complaint? Or is there a different time that would be better for that?
thanks again,
Original Message
From:
)
Sent: Monday, January 13, 2020 12:32
To:
Cc:
Subject: RE:
- Following up re proffers
Sounds good, thanks.
Original Message
From:
Sent: Monday, January 13, 2020 12:22
To:
Cc:
Subject: RE:
- Following up re proffers
Thank you. We definitely want to have this discussion prior to your decision on bringing any charges and our
understanding was that we share that goal with you. I will let you know if we work something out for next week
as soon as possible. Thanks.
Original Message
From:
Sent: Monday, January 13, 2020 12:18 PM
To:
Cc:
Subject: RE:
- Following up re proffers
,
Please let us know what days and time ranges would be even conceivably possible next week, and also if your
schedule changes at for later this week. On our end, we need to coordinate at least 10 people's schedules so we'll
need some ranges to make sure everyone who you will want to hear your presentation can attend.
EFTA00026550

=== Page 3 ===
As we mentioned on the phone, there is a strong view that there are offenses that can be charged now, so it is also
possible to have this discussion post-charge, but we certainly would prefer to have the conversation before that,
and while the issues are very fresh in everyone's minds here. Our supervisor's view is that the 30th/3 1st is a long
way off.
thanks,
Original Message
From:
Sent: Monday, January 13, 2020 12:10
To:
Cc:
i
Subject: RE:
- Following up re proffers
Understood. This week doesn't work at all. The 21st and 22nd also don't work, but if the 30th and 31st don't
work on your end, I will see if I can move some things around in order to make next week work.
Original Message
From:
Sent: Monday, January 13, 2020 12:05 PM
To:
Cc:
i
Subject: RE:
- Following up re proffers
,
We were asked to inquire regarding your availability later this week (15th to 17th) and early next (21st and
22nd), and I know the brass feels that the issues are teed up and they want to provide an opportunity to hear from
you as soon as possible. Are you available on any of those days, of it not, some other time next week?
thanks,
Original Message
From:
Sent: Monday, January 13, 2020 11:59
To:
EFTA00026551

=== Page 4 ===
Cc:
Subject: RE:
- Following up re proffers
All - Thank you for your time on the phone last week. We are following up with regard to scheduling the meeting
referenced in your earlier email. Would January 30th or 31st work (with a preference for the 31st)?
Original Message
From:
Sent: Thursday, January 9, 2020 11:00 PM
To:
Cc:
Subject: RE:
- Following up re proffers
Understood, thanks. We'll be reachable in the interim via email.
Original Message
From:
Sent: Thursday, January 09, 2020 22:57
To:
Cc:
i
Subject: Re:
- Following up re proffers
I'm trying to rearrange some things in order to call you at 11 am. Thanks.
EFTA00026552

=== Page 5 ===
On Jan 9, 2020, at 10:03 PM,
wrote:
,
We are all available just slightly later, at 11:00 a.m. - we'll be reachable at
,
or we can call you at
any number that would be convenient for you then. We'll plan to speak with you then, and no hard stop.
thanks,
From:
Sent: Thursday, January 09, 2020 19:45
To:
Cc:
Subject: RE:
- Following up re proffers
We can also do any time after 9 am, if that is better for you. Please let us know. Thanks.
From:
Sent: Thursday, January 9, 2020 7:25 PM
To:
Cc:
Subject: RE:
- Following up re proffers
Thank you for the update. Are you available to speak tomorrow at 10 am?
EFTA00026553

=== Page 6 ===
From:
Sent: Thursday, January 9, 2020 6:09 PM
To:
Cc:
Subject: RE:
- Following up re proffers
,
As we flagged for you a week ago, and as expected, we had a meeting with the office leadership today to discuss
the status of the case in general and Ms.
in particular. We continue to believe that it would be helpful to
receive any clarifications, as well as any response to the complaint originally sent on December 4, as soon as
possible; we are available tomorrow or over the weekend if there is a time that works for you. If it remains
impossible to talk before Tuesday, we have 2:30 in our calendar for then, but with a hard stop at 3:30 so please
let us know if you'd like to start the discussion earlier if you expect it might be useful to have additional time.
More generally, you had requested the opportunity to present to the ultimate decision-makers in the case if it
appeared that charges were likely, and based on our meeting today, the Office would like to provide you that
opportunity. If you could please let us know what dates and times you are available in the ranges of January 15-
17 and 21-22, we will figure out a time when all the relevant supervisors here are available. I expect that meeting
will include at least the U.S. Attorney, the Deputy U.S. Attorney
(
), and the Chief of the Criminal
Division
(
), and some combination of the Chief Counsel
), the Counsel
(
),
the two Public Corruption Unit chiefs
), the line assistants, and/or FBI
investigative and supervisory personnel. We will be prepared to discuss that meeting with you via phone when
we speak as well, which is one reason I note that we can begin our discussion earlier than 2:30 on Tuesday (or
block off significant time to talk before then) if that would be useful.
EFTA00026554

=== Page 7 ===
thank you,
Assistant U.S. Attorney
Southern District of New York
Original Message
From:
)
Sent: Sunday, January 05, 2020 18:15
To:
Cc:
Subject: RE:
- Following up re proffers
,
We'll block off that time in the calendar and plan to talk with you then.
thanks,
Original Message
From:
Sent: Saturday, January 04, 2020 22:30
To:
Cc:
Subject: Re:
- Following up re proffers
EFTA00026555

=== Page 8 ===
Sorry for the delay in my response. Unfortunately, I won't be able to address this until my return to the office.
Apologies. Of course, I will consult with
and try to get back to you as quickly as possible following my
return. In anticipation of being able to do that, do you want to "pencil in" a call for Tuesday, January 14 at 2:30?
m/>
On Jan 2, 2020, at 3:07 PM,
wrote:
EFTA00026556

=== Page 9 ===
Thanks very much for being in touch. We had actually planned to be in touch today-we expect that next week
we'll be having meaningful conversations internally with supervisors about the possible / likely paths forward
for aspects of the case including Ms.
In connection with that expectation, we wanted to ask if you were
prepared (and willing) to convey to convey your client's recollection regarding the incident described in the
complaint
sent on December 4 (re-attaching here, specifically at page seven). To the extent you have
additional information that would be helpful to convey, even minor, we would be available anytime in the
coming days to do a call. If that isn't possible until you come back, obviously we understand the challenges of
scheduling, but we had anticipated trying to see if we could schedule a call in the coming days. Please let us
know?
thanks,
Original Message
From:
Sent: Wednesday, January 01, 2020 21:50
To:
Cc:
Subject:
- Following up re proffers
All - Happy new year. Wishing you and your families a happy, healthy, and peaceful 2020. We wanted to let you
know that there are a few minor clarifications/corrections we want to share with respect to
proffers. I will
be out of the country and not returning to the office until January 10<x-apple-data-detectors://0> (or possibly
January 13<x-apple-data-detectors://1>). We will contact you then about scheduling a call to discuss. Many
thanks.
Best,
EFTA00026557

=== Page 10 ===
EFTA00026558

=== Page 11 ===
The contents of this message may be privileged and confidential. If this message has been received in error,
please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege.
Please do not disseminate this message without the permission of the author. Any tax advice contained in this
email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under
applicable tax laws and regulations.
EFTA00026559


c1: EFTA00026598
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026598.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To: "Kramer, Amanda K"
Cc:
"
)"
Bcc:
"
Subject: RE: Call
Date: Tue, 23 Feb 2021 02:11:00 +0000
Embedded: RE:_Call.msg
Sender:
Subject: RE: Call
Message-Id:
<BN3P110MB025788831F68E871C6FFFC448A809@BN3P110MB0257.NAMP110.PROD.OUTLOOK.COM
>
Cc:
EFTA00026598


c1: EFTA00026701
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026701.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Ce: Christian Everdell
Subject: [EXTERNAL] Ghislaine Maxwell 02879-509
Date: Wed, 13 Oct 2021 22:55:47 +0000
Inline-ImagesScreen_Shot_2021-10-13_at_6.46.32_PMpng Scrcn_Shot_2021-1013_at_6.3126_PM.pmg Scre_Shot_2021-1013_at_62605_PMpg
Good evening-
Per the govt email and FedEx tracking info (see below), two (2) FedEx envelopes sent by the government to the MDC
for Ms. Maxwell were delivered to the MDC yesterday (Tuesday 10/12) at 10:26 am.
As of this afternoon (10/13), Ms. Maxwell still had not received either FedEx..
Please immediately provide an explanation for the delay as it will be reported to the Court.
Bobbi
*
Yesterday at 5:58 PM
RE: [EXTERNAL] Re: Hard Drives
Details
To: BC Sternheim,
(USANYS), Cc: Christian Everdell &
7 more
Hi Bobbi,
The FedEx tracking numbers are 8166 1429 9141 and 8166 1429 9130. One is for the drive and one is for the decryptio
password.
Thanks,
Chrome File Edit View History Bookmarks Profiles Tab Window Help
L
4)) 94% C4) Wed 6:31 PM BC Sternheim
!!!
8166 1429 9130
?
ADD NICKNAME
Delivered
Tuesday, October 12, 2021 at 10:26 am
DELIVERED
Signature release on file
GET STATUS UPDATES
OBTAIN PROOF OF DELIVERY
FROM
TO
NEW YORK, NY US
Brooklyn, NY US
SEE FULL DETAILS
Personalize Your Deliveries
Need to customize this delivery?
Learn how FedEx Delivery Manager® can help
EFTA00026701

=== Page 2 ===
Safari File Edit View History Bookmarks Window Help
S
1
92%
Wed 6:26 PM BC Sternheim
<
>
fedex.com
+
FedEx®
Shipping
Tracking
Design & Print
Locations
Support
Sign Up or Log In
2
TRACK ANOTHER SHIPMENT
8166 1429 9141
?
ADD NICKNAME
Delivered
Tuesday, October 12, 2021 at 10:26 am
DELIVERED
Signature release on file
GET STATUS UPDATES
OBTAIN PROOF OF DELIVERY
FROM
TO
NEW YORK, NY US
BROOKLYN, NY US
Travel History
Shipment Facts
?
?
?
?
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.
EFTA00026702


c1: EFTA00024847
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024847.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B5
Evidence
31E-MM-108062 - 1B5
Item:
Evidence
General
Type:
(U//FOUO) One box containing: 1) FIVE MESSAGE PRINTOUTS PBPD 05-382(1) 2) WHITE PAPER C. J. (2) 3)
MESSAGE M. (3) 4) MESSAGE P.S. (4) 5) MESSAGE A. (5) 6) MESSAGE J.L. (6) 7) MESSAGE T. (7) 8) CLEAR
PLASTIC STICK (8) 9) TWELVE WHITE PAPER - EXPENDITURES PBPD 05-383(1) 10) WHITE PAPER J. (2)
11) WHITE PAPER D. (3) 12) WHITE PAPER C. (4) 13) WHITE PAPER J. (5) 14) WHITE PAPER J. (6) 15)
Description: WHITE PAPER M. (7) 16) WHITE PAPER #
(8) 17) MESSAGE A. PBPD 05-384(1) 18)
WHITE PAPER T. (2) 19) WHITE PAPER J.H. (3) 20) WHITE PAPER F. (4) 21) MESSAGE G.D. (5) 22)
MESSAGE # (6) 23) MESSAGE M.M. H. (7) 24) WHITE PAPER C.W. (8) WHITE PAPER (917) PBPD 05-
385(1) 26) WHITE PAPER A. (2) 27) WHITE PAPER E. (3) 28) WHITE PAPER B. F. (4) 29) WHITE PAPER
S.B.
(5) 30) FOUR WHITE PAPERS (6)
Location:
E03707388 ECR8
E4640430 ECR8, 14
Barcode:
E6516715
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery Location
Holding Office: NY - NEW YORK
Area:
Unavailable in data migrated from
Finalized By:
=
ACS
Last Inventory: 07/20/2021 12:00 AM
Seizing Individual:
None
Other Seizing
Il
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
=
Retention
Retention: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
EFTA00024847

=== Page 2 ===
Chain of Custody FD-192
E6516715
Case ID : 31E-MM-108062
1B5
Barcode
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
Printed Name:
Signature: yll-
Reason:
STORAGE.
Date/Time: 2-8-08
330PM.
Accepted By:
Printed Name:.
Signature: yea-
Reason:
RELEASED TO SA.
Date/Time: 4-10-08
1100AM.
Accepted By:
Printed Name:
Signature:
Reason: Review
Date/Time: 04/10/2008 11.01am
Accepted By:
Printed Name:
Signature:
Reason: Return of all IBs
Date/Time: 01/13/2009 3:14PM
Accepted By:
Printed Name:
Signature: see
Reason:
STORAGE
Date/Time: 01-13-09
315PM
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Reason:
RF
Signature:
Date/Time:
Accepted By:
Printed Name:
Reason:
6/14/19
Signature:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
EFTA00024848

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody fed EX#: 478344676382
Date and
Signature:
6/17/19
Accepted Signature: Custody WO
Date and
Time
Time
Printed Name/Agency
FBI
Printed Name/Agency:
6/20/19
Reason: Transferred to NY
9:35am
145284 03113232 Reason:
Relinquished Custody
3:00PM
CMO
Date and
Accepted Custody
MIAMI
Date and
Time
51/12/9
Time
Signature:
Signature:
Printed Name/Agency
6/24/19
Reason:
10
Printed Name/Agency:
2:6/19 Date and
Reason:
2:10p
Relinquished Custody
Accepted Custody
Date and
Time
Signature:
9/26/19
Signature all
Time
Printed Name/Agency
FBI
9/26/19
Relinquished Custody Storage
Reason:
2:20p
Date and
Accepted Reason Printed Chipsoy Name/Agen Custody
pn
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 5
Barcode: E4229232 E6516715
This form is incomplete without reference to the FD-1087.
EFTA00024849


c1: EFTA00024435
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024435.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10586462 approved by
, now awaiting further
approval
Date: Thu, 29 Aug 2019 22:11:05 +0000
Importance: Normal
Dear
Travel authorization 10586462 has been approved by
, now awaiting further approval.
Trip ID: 10586462
Traveler name:
Purpose: R19NYS13781 - U.S. V. Epstein - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-03 - 2019-09-04
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
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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.
EFTA00024435


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=== Page 1 ===
From:
To:
Subject: Re: United States V. Ghislaine Maxwell --
Date: Sun, 28 Nov 2021 15:11:33 +0000
You are awesome. Good luck this week - let me know if there's anything you need help with.
On Nov 28, 2021, at 9:59 AM,
wrote:
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
EFTA00024896


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=== Page 1 ===
From:
To:
Subject: Epstein Mansions in New York and Palm Beach for Sale for $110 Million - The New York Times
Date: Thu, 23 Jul 2020 16:23:57 +0000
https://www.nytimes.com/2020/07/23/nyregion/jeffey-epstein-address-homes.html
Sent from my iPhone
EFTA00024722


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=== Page 1 ===
From:
To:
Subject: Accepted: Proffer
Date: Wed, 10 Jul 2019 18:42:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00026688


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=== Page 1 ===
From:
To:
Subject: Fwd: Scanned from a Xerox Multifunction Printer
Date: Wed, 10 Jul 2019 16:08:16 +0000
Attachments: Epstein_USMS_312.pdf; ATT00001.htm
More arrest paperwork with his cell phone number listed.
Begin forwarded message:
From:
"
"
Date: July 10, 2019 at 11:33:40 EDT
To:
"
"
,
Subject: Scanned from a Xerox Multifunction Printer
Reply-To:
Please open the attached document. It was scanned and sent to you using a Xerox Multifunction Printer.
Attachment File Type: pdf, Multi-Page
Multifunction Printer Location:
Device Name: P290BWAY-MSSTF-MFD
For more information on Xerox products and solutions, please visit http://www.xerox.com
EFTA00026659


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=== Page 1 ===
EXHIBIT A: LEON BLACK / ROTHSCHILD GROUP TRANSACTIONS
DATE
PAYER
RECIPIENT
AMOUNT
BATES #
10/15/2013
Leon and Debra Black
Southern Trust Company, Inc.
$8,500,000
DB-SDNY-0002962
12/18/2013
Black Family Partners, LP c/o Apollo
Southern Trust Company, Inc.
$10,000,000
DB-SDNY-0003484
Management
4/25/2014
Leon and Debra Black
Southern Trust Company, Inc.
$5,000,000
DB-SDNY-0003819
4/25/2014
Black Family Partners, LP c/o Apollo
Southern Trust Company, Inc.
$5,000,000
DB-SDNY-0003819
Management
4/29/2014
Leon and Debra Black
Southern Trust Company, Inc.
$15,000,000
DB-SDNY-0003819
7/15/2014
Narrow Holdings LLC c/o Elysium
Southern Trust Company, Inc.
$20,000,000
DB-SDNY-0004009
Management
10/16/2014
Leon and Debra Black
Southern Trust Company, Inc.
$7,000,000
DB-SDNY-0004172
10/16/2014
Black Family Partners, LP c/o Apollo
Southern Trust Company, Inc.
$13,000,000
DB-SDNY-0004172
Management
10/22/2014
Leon and Debra Black c/o Apollo Management
Southern Trust Company, Inc.
$2,000,000
DB-SDNY-0004173
10/22/2014
Black Family Partners, LP c/o Apollo
Southern Trust Company, Inc.
$3,000,000
DB-SDNY-0004173
Management
10/13/2015
Leon and Debra Black c/o Apollo Management
Southern Trust Company, Inc.
$5,000,000
DB-SDNY-0004990
10/13/2015
Black Family Partners, LP c/o Apollo
Southern Trust Company, Inc.
$5,000,000
DB-SDNY-0004990
Management
10/14/2015
BV70 LLC
Gratitude America, Ltd.
$10,000,000
DB-SDNY-0004999
12/17/2015
Edmond de Rothschild (Suisse) SA Geneva,
Southern Trust Company, Inc.
$10,000,000
DB-SDNY-0005122
Switzerland
12/18/2015
Black Family Partners, LP
Southern Trust Company, Inc.
$10,000,000
DB-SDNY-0005122
12/21/2015
Benjamin Edmond de Rothschild
Southern Trust Company, Inc.
$14,999,980
DB-SDNY-0005122
12/30/2015
Leon and Debra Black c/o Apollo Management
Southern Trust Company, Inc.
$10,000,000
DB-SDNY-0005123
3/31/2017
BV70 LLC
Plan D, LLC
$22,500,000
DB-SDNY-0006113
4/17/2017
BV70 LLC
Plan D, LLC
$8,000,000
DB-SDNY-0006197
4/25/2017
Leon and Debra Black c/o Apollo Management
Southern Trust Company, Inc.
$8,000,000
DB-SDNY-0006240
10/2/2018
Plan D, LLC
BV 70th LLC¹
$10,000,000
DB-SDNY-0007669
I Please note that the account statement for this transaction lists the entity as "BV 70th LLC" instead of "BV70 LLC.
EFTA00027019

=== Page 2 ===
EXHIBIT B: TRANSACTIONS INVOLVING HEDGE / INVESTMENT FUNDS
DATE
PAYER
RECIPIENT
AMOUNT
BATES #
5/2/2014
Southern Financial LLC
Boothbay Multi Strategy Fund LP
$10,000,000
DB-SDNY-0003845
Barack Ferrazzano Kirschbaum and
5/14/2014
Southern Financial LLC
$99,999
DB-SDNY-0003846
Nagelberg Client Fund²
7/2/2014
Southern Financial LLC
Joichi Ito
$250,000
DB-SDNY-0003972
8/4/2014
Tudor Futures Fund
Southern Financial LLC
$12,826,541
DB-SDNY-0004032
8/8/2014
Tudor Futures Fund
Southern Financial LLC
$677,400
DB-SDNY-0004032
9/9/2014
Southern Financial LLC
Joichi Ito3
$500,001
DB-SDNY-0004084
1/21/2015
Southern Trust Company, Inc.
Valar Global Fund II LP
$150,000
DB-SDNY-0004346
2/12/2015
Southern Trust Company, Inc.
Valar Global Fund II LP
$900,000
DB-SDNY-0004412
3/12/2015
Southern Financial LLC
Joichi Ito4
$250,000
DB-SDNY-0004441
3/30/2015
Southern Trust Company, Inc.
Valar Global Fund II LP
$2,700,000
DB-SDNY-0004487
4/13/2015
Southern Financial LLC
Neoteny 3, LP
$1,000,000
DB-SDNY-0004518
6/30/2015
Southern Financial LLC
Boothbay Absolute Strategies Fund LP
$2,000,000
DB-SDNY-0004675
7/24/2015
Southern Trust Company, Inc.
Valar Global Fund II LP
$600,000
DB-SDNY-0004790
7/28/2015
Southern Financial LLC
Boothbay Absolute Strategies Fund LP
$7,000,000
DB-SDNY-0004745
8/5/2015
Joichi Ito
Southern Financial LLC
$483,915
DB-SDNY-0004815
9/24/2015
Southern Trust Company, Inc.
Valar Global Fund II LP
$1,950,000
DB-SDNY-0004924
9/28/2015
Southern Financial LLC
Boothbay Absolute Strategies Fund LP
$4,250,000
DB-SDNY-0004881
3/1/2016
Southern Financial LLC
Boothbay Absolute Strategies Fund LP
$10,000,000
DB-SDNY-0005280
3/31/2016
Southern Financial LLC
Boothbay Absolute Strategies Fund LLP
$5,000,000
DB-SDNY-0005281
5/31/2016
Southern Trust Company, Inc.
Honeycomb Partners LP
$20,000,000
DB-SDNY-0005457
6/23/2016
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$250,000
DB-SDNY-0005526
8/18/2016
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$1,250,000
DB-SDNY-0005667
12/2/2016
Kyara Investments I
Southern Financial LLC
$10,000
DB-SDNY-0005882
12/12/2016
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$3,750,000
DB-SDNY-0005932
2 Wire details read: "Southern Financial LLC investment in Kyara Investments LLC." See DB-SDNY-0000478.
3 Wire details read: "suber to Kyara Investments III, LLC to fund Blockstream Investment." See DB-SDNY-0000478.
4 Wire details read: "suber to Kyara Investment IV, LLC to fund OH2 Laboratories." See DB-SDNY-0000478.
EFTA00027020

=== Page 3 ===
DATE
PAYER
RECIPIENT
AMOUNT
BATES #
1/6/2017
Boothbay Absolute Return Strategies LP
Southern Financial LLC
$10,000,000
DB-SDNY-0005951
4/20/2017
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$3,000,000
DB-SDNY-0006240
5/5/2017
Southern Financial LLC
Coatue Enterprises LLC
$500,000
DB-SDNY-0000478
7/10/2017
Southern Trust Company, Inc.
Honeycomb Ventures I LP
$1,000,000
DB-SDNY-0006407
7/24/2017
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$4,250,000
DB-SDNY-0006407
10/11/2017
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$2,250,000
DB-SDNY-0006652
1/5/2018
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$1,500,000
DB-SDNY-0006901
1/12/2018
Southern Financial LLC
Coatue Enterprises LLC
$500,000
DB-SDNY-0006847
2/15/2018
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$500,000
DB-SDNY-0006985
2/21/2018
Blockchain Capital IV, LP
The 2017 Caterpillar Trust
$10,500,000
DB-SDNY-0006982
Blockchain Capital III Digital Liquid
2/21/2018
Venture Fund, LP
The 2017 Caterpillar Trust
$2,625,000
DB-SDNY-0006982
2/21/2018
Blockchain Capital Parallel Fund IV, LP
The 2017 Caterpillar Trust
$1,875,000
DB-SDNY-0006982
4/20/2018
Neoteny 3 LP
Southern Financial LLC
$30,000
DB-SDNY-0007110
6/1/2018
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$1,750,000
DB-SDNY-0007348
6/13/2018
Southern Financial LLC
Coatue Enterprises LLC
$500,000
DB-SDNY-0007289
6/27/2018
Southern Trust Company, Inc.
Honeycomb Partners LP
$10,000,000
DB-SDNY-0007348
6/28/2018
Southern Trust Company, Inc.
Honeycomb Partners LP
$5,000,000
DB-SDNY-0007348
9/5/2018
Kyara Investments I
Southern Financial LLC
$11,392
DB-SDNY-0007568
9/28/2018
Southern Trust Company, Inc.
Honeycomb Partners LP
$8,000,000
DB-SDNY-0007623
11/20/2018
Southern Financial LLC
Coatue Enterprises LLC
$500,000
DB-SDNY-0007748
1/8/2019
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$2,500,000
DB-SDNY-0007987
3/13/2019
The 2017 Caterpillar Trust
Honeycomb Ventures IV LP
$10,000,000
DB-SDNY-0008151
3/28/2019
Southern Trust Company, Inc.
Honeycomb Partners LP
$10,000,000
DB-SDNY-0008154
4/17/2019
Southern Trust Company, Inc.
Valar Globaal Fund III LP
$1,500,000
DB-SDNY-0008222
EFTA00027021

=== Page 4 ===
EXHIBIT C: CAPITALIZATION OF JEFFREY EPSTEIN'S Now/SuperNow ACCOUNTS5
DATE
PAYER
RECIPIENT6
AMOUNT
BATES #
10/11/2013
Jeepers Inc. (DB Brokerage Account)
$3,000,000
DB-SDNY-0002926
11/13/2013
Barry Jay Josephson
$200,000
DB-SDNY-0002992
11/14/2013
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0002994
12/20/2013
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0003427
1/24/2014
$225,000
DB-SDNY-0003538
1/30/2014
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0003538
2/18/2014
Adam Bly
$7,500
DB-SDNY-0003640
2/20/2014
Jeepers Inc. (DB Brokerage Account)
$4,000,000
DB-SDNY-0003640
3/18/2014
Adam Bly
$3,500
DB-SDNY-0003709
4/11/2014
Jeepers Inc. (DB Brokerage Account)
$3,400,000
DB-SDNY-0003769
5/6/2014
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0003832
5/16/2014
Island Global Yachting LTD
$292,655
DB-SDNY-0003833
5/21/2014
Michelle Saipher / Darren Indyke
$698,000
DB-SDNY-0003833
5/21/2014
Michelle Saipher / Darren Indyke
$525,000
DB-SDNY-0003834
6/11/2014
Jeepers Inc. (DB Brokerage Account)
$3,000,000
DB-SDNY-0003896
7/16/2014
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0003960
8/19/2014
Jeepers Inc. (DB Brokerage Account)
$2,500,000
DB-SDNY-0004022
9/17/2014
Adam Bly
$3,000
DB-SDNY-0004074
10/2/2014
Jeepers Inc. (DB Brokerage Account)
$2,500,000
DB-SDNY-0004126
10/15/2014
Adam Bly
$3,000
DB-SDNY-0004127
11/14/2014
Adam Bly
$7,500
DB-SDNY-0004183
11/17/2014
Jeffrey E Epstein c/o HBRK Associates (Non-DB Account)
$1,928,647
DB-SDNY-0004183
11/21/2014
Adam Bly
$100,000
DB-SDNY-0004184
1/5/2015
Jeepers Inc. (DB Brokerage Account)
$2,500,000
DB-SDNY-0004296
5 According to KYC records, Jeffrey Epstein used the Now/SuperNow accounts (also referred to as "Elite Checking with Interest") for his "personal daily use." See DB-
SDNY-0002607. The attached chart reflects incoming wire transfers from Deutsche Bank brokerage accounts and accounts held at third party financial institutions. The chart
does not capture internal cash transfers between Deutsche Bank deposit accounts.
6 In early 2016, Jeffrey Epstein moved his assets from one Now/SuperNow account to a different Now/SuperNow account. We are still unclear as to why this transition
occurred, but expect electronic communications to provide additional insight. To date, the only functional difference between the two accounts that we have identified is the
account number, which is reflected in the "Recipient" column.
EFTA00027022

=== Page 5 ===
DATE
PAYER
RECIPIENT6
AMOUNT
BATES #
2/10/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004359
3/9/2015
Adam Bly
$10,484
DB-SDNY-0004431
3/13/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004431
3/27/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004432
4/16/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004509
5/18/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004587
6/3/2015
Adam Bly
$10,484
DB-SDNY-0004665
6/12/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004665
7/6/2015
AIC Title Agency
$2,000,000
DB-SDNY-0004735
7/9/2015
Jeepers Inc. (DB Brokerage Account)
$3,200,000
DB-SDNY-0004736
8/13/2015
Seed Media Group
$170,000
DB-SDNY-0004806
8/20/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004807
10/7/2015
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0004937
10/19/2015
Stone & Magnanini LLP
$1,000,000
DB-SDNY-0004937
10/29/2015
Jeepers Inc. (DB Brokerage Account)
$2,500,000
DB-SDNY-0004938
11/13/2015
Kellerhals Ferguson Kroblin PLLC
$23,000,000
DB-SDNY-0005003
1/8/2016
The Haze Trust (DB Brokerage Account)
$20,000,000
DB-SDNY-0005135
2/2/2016
Kellerhals Ferguson Kroblin PLLC
$75,000
DB-SDNY-0005201
4/19/2016
Gol Muchnik
$500,000
DB-SDNY-0005342
9/9/2016
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0005683
9/28/2016
Jeffrey Epstein (Non-DB Account)
$700,000
DB-SDNY-0005684
10/7/2016
Delson International Inc.
$50,000
DB-SDNY-0005747
10/26/2016
Jeepers Inc. (DB Brokerage Account)
$2,000,000
DB-SDNY-0005748
10/27/2016
Delson International Inc.
$50,574
DB-SDNY-0005749
7/18/2017
Sultan Bin Sulayem
$6,200
DB-SDNY-0006349
10/26/2017
Jamie Mitchell
$100,000
DB-SDNY-0006594
12/20/2017
NLR Resorts International LLC
$50,000
DB-SDNY-0006756
1/16/2018
NLR Resorts International LLC
$25,000
DB-SDNY-0006839
1/23/2018
NLR Resorts International LLC
$25,000
DB-SDNY-0006839
3/30/2018
David J Mitchell
$50,000
DB-SDNY-0007012
9/18/2018
David J Mitchell
$50,000
DB-SDNY-0007561
9/28/2018
Jeffrey Epstein (Non-DB Account)
$700,000
DB-SDNY-0006510
EFTA00027023

=== Page 6 ===
DATE
PAYER
RECIPIENT6
AMOUNT
BATES #
10/11/2018
David J Mitchell
$125,000
DB-SDNY-0007651
10/24/2018
David J Mitchell
$10,000
DB-SDNY-0007652
10/25/2018
Link Rockenbach P.A.
$3,000,000
DB-SDNY-0007653
11/9/2018
David J Mitchell
$80,000
DB-SDNY-0007741
12/13/2018
David J Mitchell
$50,000
DB-SDNY-0007834
1/10/2019
David J Mitchell
$100,000
DB-SDNY-0007924
1/11/2019
Jeffrey Epstein (Non-DB Account)
$100,000
DB-SDNY-0007924
2/7/2019
Jeepers Inc. (DB Brokerage Account)
$3,276,640
DB-SDNY-0008016
3/5/2019
David J Mitchell
$25,000
DB-SDNY-0008097
3/5/2019
David J Mitchell
$14,000
DB-SDNY-0008097
3/5/2019
David J Mitchell
$4,000
DB-SDNY-0008097
3/18/2019
David J Mitchell
$5,500
DB-SDNY-0008099
4/1/2019
David J Mitchell
$3,000
DB-SDNY-0008179
4/2/2019
$54,000
DB-SDNY-0008180
4/11/2019
David J Mitchell
$7,800
DB-SDNY-0008181
4/12/2019
David J Mitchell
$2,200
DB-SDNY-0008181
EFTA00027024

=== Page 7 ===
EXHIBIT D: TRANSACTIONS INVOLVING THE HAZE TRUST ACCOUNTS
DATE
PAYER
RECIPIENT
AMOUNT
BATES #
3/10/2017
The Haze Trust Brokerage (
)
The Haze Trust Checking (
)
$36,000,000
DB-SDNY-0006153
3/10/2017
The Haze Trust Checking (
)
The Haze Trust DBAGNY
(
)
$35,999,000
DB-SDNY-0006153
3/27/2017
The Haze Trust DBAGNY
(
)
Plan D, LLC Checking (
)
$15,000,000
DB-SDNY-0006168
6/19/2017
Christie's Inc.
The Haze Trust Checking (
)
$7,725,000
DB-SDNY-0006320
9/25/2017
Sotheby's
The Haze Trust Checking (
)
$11,536,544
DB-SDNY-0006565
9/26/2017
The Haze Trust Checking
(
)
The Haze Trust DBAGNY
(
)
$15,000,000
DB-SDNY-0006565
10/24/2017
Sotheby's
The Haze Trust Checking (
)
$11,249,417
DB-SDNY-0006646
10/26/2017
The Haze Trust Checking (
)
The Haze Trust DBAGNY
(
)
$13,000,000
DB-SDNY-0006646
6/22/2018
The Haze Trust DBAGNY
(
)
Southern Financial LLC Checking (
)
$9,000,000
DB-SDNY-0007361
8/20/2018
The Haze Trust DBAGNY
(
)
Southern Financial LLC Checking (
)
$5,000,000
DB-SDNY-0007544
9/17/2018
The Haze Trust DBAGNY
(
)
Southern Financial LLC DBAGNY
(
)
$5,000,000
DB-SDNY-0007635
9/28/2018
The Haze Trust DBAGNY
(
)
Southern Financial LLC Checking (
)
$8,000,000
DB-SDNY-0007635
10/1/2018
The Haze Trust DBAGNY
(
)
Southern Trust Company Checking (
)
$10,000,000
DB-SDNY-0007725
10/24/2018
The Haze Trust DBAGNY
(
)
Southern Financial LLC Checking (
)
$5,000,000
DB-SDNY-0007725
11/20/2018
The Haze Trust Checking (
)
Southern Financial LLC Checking (
)
$2,500,000
DB-SDNY-0007798
12/13/2018
HSBC Bank Bermuda Limited 11
The Haze Trust Checking
(
)
$58,328
DB-SDNY-0007888
12/19/2018
The Haze Trust DBAGNY
(
)
Southern Financial LLC Checking (
)
$5,000,000
DB-SDNY-0007908
1/10/2019
The Haze Trust DBAGNY
(
)
The Haze Trust Checking (
)
$2,727,941
DB-SDNY-0007979
1/10/2019
The Haze Trust Brokerage (
)
The Haze Trust Checking (
)
$6,000,000
DB-SDNY-0007979
2/7/2019
The Haze Trust Checking (
)
Southern Financial LLC Checking (
)
$8,791,283
DB-SDNY-0008063
2/19/2019
The Haze Trust Brokerage (
)
The Haze Trust Checking (
)
$12,608,253
DB-SDNY-0008064
2/19/2019
The Haze Trust Brokerage (
)
The Haze Trust Checking (
)
$167,414
DB-SDNY-0008064
2/19/2019
Southern Financial LLC Checking (
)
The Haze Trust Checking (
)
$11,715,364
DB-SDNY-0008063
2/19/2019
Jeffrey Epstein Checking (
)
The Haze Trust Checking (
)
$7,000,000
DB-SDNY-0008063
2/22/2019
The Haze Trust Checking (
)
Jeffrey Epstein Checking (
)
$7,000,000
DB-SDNY-0008063
2/22/2019
The Haze Trust Checking
(
)
Southern Financial LLC Checking (
)
$24,564,037
DB-SDNY-0008063
7
The below chart reflects the flow of money through two deposit accounts and one brokerage account belonging to "The Haze Trust." The Haze Trust Checking account
was opened with Deutsche Bank Trust Company Americas. The Haze Trust DBAGNY account was opened with Deutsche Bank's New York branch office. The latter account
offers higher interest rates than the former. We have yet to determine how the Haze Trust Brokerage account was initially capitalized.
EFTA00027025

=== Page 8 ===
EXHIBIT E: TRANSACTIONS INVOLVING GRATITUDE AMERICA MONEY MARKET DEPOSIT ACCOUNT ("MMDA")⁸
DATE
PAYER
RECIPIENT
AMOUNT
BATES #
10/14/2015
BV70 LLC
Gratitude America, LTD
(
)
$10,000,000
DB-SDNY-0004999
1/7/2016
Gratitude America MMDA (
)
Bruce and Marsha Moskowitz Foundation9
$50,000
DB-SDNY-0005198
Gratitude America Ltd
$50,000
DB-SDNY-0005198
1/21/2016
Gratitude America MMDA (
)
(First Bank of Puerto Rico)
1/29/2016
Gratitude America MMDA (
)
Melanoma Research Alliance Foundation
$225,000
DB-SDNY-0005198
2/3/2016
Gratitude America MMDA (
)
Gratitude America Checking (
)
$150,000
DB-SDNY-0005264
Gratitude America Ltd.
$5,000,000
DB-SDNY-0005334
3/2/2016
Gratitude America MMDA (
)
(Morgan Stanley / Citibank)¹⁰
3/8/2016
Gratitude America MMDA (
)
Gratitude America Checking (
)
$250,000
DB-SDNY-0005334
3/8/2016
Gratitude America MMDA (
)
Gratitude America Checking (
)
$250,000
DB-SDNY-0005334
Gratitude America Ltd
$250,000
DB-SDNY-0005401
4/6/2016
Gratitude America MMDA (
)
(First Bank of Puerto Rico)
7/12/2016
Gratitude America MMDA (
)
Bruce and Marsha Moskowitz Foundation
$50,000
DB-SDNY-0005605
Gratitude America Ltd.
$2,000,000
DB-SDNY-0005605
7/14/2016
Gratitude America MMDA
(
)
(Morgan Stanley / Citibank)
Gratitude America Ltd.
$500,000
DB-SDNY-0005605
7/19/2016
Gratitude America MMDA (
)
(Morgan Stanley / Citibank)
1/20/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$200,000
DB-SDNY-0006006
3/6/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$250,000
DB-SDNY-0006165
6/1/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$250,000
DB-SDNY-0006333
6/7/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$200,000
DB-SDNY-0006333
10/2/2017
Gratitude America MMDA (
)
Cancer Research Wellness Institute
$25,000
DB-SDNY-0006658
11/1/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$50,000
DB-SDNY-0006739
8 The Gratitude America MMDA was primarily capitalized via a $10 million deposit from BV70 LLC. Bloomberg has reported that Leon Black controls BV70 LLC. See
Tom Metcalf, Jeffrey Epstein's Endgame: One Last Shot to Stay in Wall Street's Favor, Bloomberg (August 6, 2019), available at:
https://www.bloomberg.com/news/articles/2019-08-06/epstein-s-endgame-one-last-shot-to-stay-in-wall-street-s-favol Exhibit E demonstrates how those funds were spent.
9 Account statements reflect that this payment was made to "First Clearing LLC." However, wire records clarify that the payment was intended for the Bruce and Marsha
Moskowitz Foundation. See DB-SDNY-0000478.
10 Account statements reflect that his payment was made to "Morgan Stanley." However, wire records indicate that the payment was intended for an account held by
Gratitude America Ltd. See DB-SDNY-0000478.
EFTA00027026

=== Page 9 ===
DATE
PAYER
RECIPIENT
AMOUNT
BATES #
11/1/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$100,000
DB-SDNY-0006739
11/13/2017
Gratitude America MMDA (
)
Gratitude America Checking (
)
$100,000
DB-SDNY-0006739
12/6/2017
Gratitude America MMDA (
)
Bruce and Marsha Moskowitz Foundation
$50,000
DB-SDNY-0006822
Gratitude America Ltd
$150,000
DB-SDNY-0006822
12/11/2017
Gratitude America MMDA (
)
(First Bank of Puerto Rico)
12/11/2017
Gratitude America Checking (
)
Gratitude America MMDA (
)
$2,500,000
DB-SDNY-0006822
1/30/2018
Gratitude America MMDA (
)
Gratitude America Checking (
)
$2,000,000
DB-SDNY-0006907
2/28/2018
Gratitude America MMDA (
)
Cancer Reasearch Wellness Institute
$25,000
DB-SDNY-0006991
4/2/2018
Gratitude America MMDA (
)
NPO Baleto Teatras
$18,493
DB-SDNY-0007170
9/17/2018
Gratitude America MMDA (
)
VSJ Baleto Teatras
$10,000
DB-SDNY-0007629
1/10/2019
Gratitude America MMDA (
)
Gratitude America Checking (
)
$314,876
DB-SDNY-0007994
EFTA00027027


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: Epstein Documents from BOP without Green Watermark
Date: Sun, 11 Apr 2021 16:26:42 +0000
and
I recall that at some point you requested a version of the Epstein FOIA documents from BOP without the translucent
green watermark they put on the withheld documents. Do you have those saved down somewhere? Although the Court
has not put in a specific order yet, I think it's likely that we'll need to produce documents without the translucent green
marking to the Court. I have versions without the watermark for some of the docs, but it looks like not all. Do you have a
comprehensive set somewhere?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
EFTA00023914


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=== Page 1 ===
From:
Cc:
Subject: RE: Epstein victim call
Date: Wed, 17 Mar 2021 18:22:02 +0000
H
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:
(
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:
(
Cc:
is
Subject: FW: Epstein victim call
Hi
and
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
is
EFTA00024028

=== Page 2 ===
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 Distric
EFTA00024029


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Subject: Accepted: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:28:27 +0000
Importance: Normal
Attachments: unnamed
EFTA00025209


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=== Page 1 ===
July 10, 2020
VIA E-MAIL
Re:
Grand Jury Subpoena Issued to
dated June 29, 2020 -
Ghislaine Maxwell, et al.
Our Matter No.:
Dear
On behalf of
("
"), this letter is in response to the Grand Jury Subpoena dated June
29, 2020 in which information and documentation with respect to the matter referenced above was requested. Enclosed
please find a WinZip file containing the items described within:
Account Records
Account Number
Description of Documents
XX X5172
Account Opening Documents and Accounts Statements
requests that, unless otherwise required by law or court order, the enclosed documents be kept confidential and
not disclosed to any third party outside the context of the above referenced legal proceeding.
also requests
advance notice of any decision to disclose any of the documents provided pursuant to this request. The WinZip file is
password protected. Please use WinZip to unzip and view the documents. Please email me at
upon receipt for the necessary password. If you have any questions, please feel free to contact me.
Sincerely,
cc: AUSA.
is a subsidiary of
EFTA00024449


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Sat, 10 Aug 2019 21:58:45 +0000
- thanks very much for being in touch, and it turns out that the primary point of
contact from our Office will be
who is copied here but also her full contact info is:
Anything at all we can do, please don't hesitate to let us know, and l'll defer to
to reach out to follow up separately.
And thanks very much for all of your work today- not how any of us expected to spend this Saturday so we really
appreciate everybody jumping in right away and making so much progress.
thanks again,
From:
Sent: Saturday, August 10, 2019 17:15
To:
)
Cc:
Subject: Epstein
,
It was nice speaking with all of you and I appreciate the offer of assistance on this.
Please see the AUSA team copied here and reach out to them for any assistance you may need from SDNY.
Thanks,
Supervisory Special Agent
FBI/NYPD
Violent Crimes Task Force
On Aug 10, 2019 4:50 PM,
)"
wrote:
-
I am cc'ing our team for you to connect them with the relevant agents on your side.
Thanks very much,
EFTA00024498


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=== Page 1 ===
From:
To: Jason Foy
Cc:
Subject: US V. Tova Noel, 19 Cr. 830 (AT) - Discovery
Date: Mon, 20 Jul 2020 22:04:06 +0000
Attachments: 2020.07.20_Response_to_Noel_June_5_Discovery_Requests_FINAL.pdf
Hello Jason,
With apologies for the delay, attached please find our response to your recent discovery request. We are also producing
some supplemental discovery by USAfx this evening.
Best,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00023755


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=== Page 1 ===
90A-NY-3151227 Serial 36
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027709
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027709: One (1) Seagate
Barracuda 1000GB HDD, ST1000DM003, S/N W1D496N0, containing the Clone
Copy of 1B10 hard drive (Seagate Barracuda 500GB HDD, ST3500320NS, S/N
9QM8MSEZ), collected via Tableau TD3-B S/N 11D350F6-1525. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027709: One (1) Seagate Barracuda 1000GB HDD,
ST1000DM003, S/N W1D496N0, containing the Clone Copy of
1B10 hard drive (Seagate Barracuda 500GB HDD,
ST3500320NS, S/N 9QM8MSEZ), collected via Tableau TD3-B
S/N 11D350F6-1525. Request ID 112048. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Derivative
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00025427

=== Page 2 ===
90A-NY-3151227 Serial 36
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027709
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00025428


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=== Page 1 ===
From:
To:
Subject: pros memo / flight stuff
Date: Wed, 09 Oct 2019 20:30:33 +0000
Attachments: 2019-06-17,_JE,_prosecution_memo.docx
Hey, so unfortunately the open-source website that tracked private planes (even those that paid to be de-listed on public
trackers, such as your target jet) is currently down as of just a couple days ago:
https://adsbexchange.com/flight-data-sgl-archive/
If it comes back up, may be of use, otherwise you may have to rely on international flight records.
And pros memo attached, as promised - again, don't hesitate to be in touch if anything else would be useful, whether in
the near term or further along in your investigation. Good luck!
Assistant U.S. Attorney
Southern District of New York
EFTA00025380


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=== Page 1 ===
From: Gloria Allred
To:
)"
Cc:
)"
)"
Subject: RE: Call today
Date: Thu, 21 May 2020 21:21:32 +0000
Inline-Images: image001.png; image002.png
I will. Thank you.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
323-653-6530
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Thursday, May 21, 2020 2:18 PM
To: Gloria Allred
Cc:
is
Subject: Re: Call today
Yes that works, thanks very much. We can use the below dial in:
On May 21, 2020, at 4:40 PM, Gloria Allred
> wrote:
Yes. May I call you at 6P.M. e.s.t.? Would you like me to send a conference call number or just call your office below?
EFTA00026532

=== Page 2 ===
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
323-653-6530
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Thursday, May 21, 2020 12:21 PM
To: Gloria Allred
Cc:
is
Subject: Call today
Gloria,
Would you be available for a quick call this afternoon? We have a couple quick questions for you relating to the Epstein
case. I'm available to talk any time.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT 323-653-6530. Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT 323-653-6530. Thank you.
EFTA00026533


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
Date: Fri, 29 Oct 2021 22:08:58 +0000
Attachments: GM_Legal_Mail_Delivery_Request_10-29-21.pdf
Please see the attached letter, which was filed this evening. Are you available for a call on Monday? We anticipate that
this issue will be addressed at our final pretrial conference at 11 a.m. on Monday.
Thanks,
From: BOBBI C STERNHEIM
Sent: Friday, October 29, 2021 5:57 PM
To:
is
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: [EXTERNAL] US V. Maxwell S2 20 Cr 330 (AJN)
Courtesy copy of today's ECF filing.
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main:
Cell:
Fax:
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.
EFTA00024170


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
Subject: Re: Jeffrey Epstein friend Ghislaine Maxwell under FBI investigation
Date: Fri, 27 Dec 2019 15:47:51 +0000
,
give me a call when you have a chance. Geoff
> On Dec 27, 2019, at 9:36 AM,
wrote:
V
>
https://www.cnbc.com/2019/12/27/jeffrey-epstein-friend-ghislaine-maxwell-under-fbi-investigation.html
>
V
> Sent from my iPhone
EFTA00023968


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=== Page 1 ===
From
To
Subject: FW: United States V. Ghislaine Maxwell
Date: Sun, 28 Nov 2021 15:31:32 +0000
From
Sent: Sunday, November 28, 2021 9:59 AM
To:
Cc:
Subject: United States V. Ghislaine Maxwell --
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
EFTA00024898


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=== Page 1 ===
From:
To: "Moore, Amanda G. (NY) (FBI)"
Subject: Fwd: Then #10
Date: Mon, 25 May 2020 17:33:27 +0000
Inline-Images: IMG_1292.JPG
Begin forwarded message:
From: STACEY RICHMAN
Date: May 25, 2020 at 1:09:48 PM EDT
To:
Subject: Fw: Then #10
STACEY RICHMAN
Law Offices of
Richman Hill & Associates PLLC
2027 Williamsbridge Road
Bronx, New York 10461
(Main)
(718) 518-0674 (Facsimile)
***Confidentiality Notice***
This email and any accompanying documents contains information that is intended only for the use of the
individual or entity to whom it is addressed and may contain information that is legally privileged, confidential
or otherwise exempt from disclosure under applicable laws. If the reader of this message is not the recipient,
any disclosure, dissemination, distribution, copying, or other use or retention of this communication or its
substance is prohibited. If you have received this email in error, please delete it and notify the sender by return
email. Thank you.
From: Mark L. Epstein
Sent: Sunday, May 24, 2020 6:47 PM
To: STACEY RICHMAN
Subject: Then
EFTA00026540

=== Page 2 ===
3G
+16203229434(8/8)
05/24 09:43 am
You will diiiie
like your brother,
wait for us
grat.in/uxdyd
05/24 10:11 am
Look behind you.
Options Expand
Reply
LG
in can and string.


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: 3500 cover letter
Date: Mon, 25 Oct 2021 21:10:23 +0000
Attachments: 2021.10.25_Maxwell_Cover_Letter_v1.docx
Edit freely
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00025034


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=== Page 1 ===
From:
To:
Subject: Proffer
Date: Wed, 10 Jul 2019 18:42:07 +0000
Importance: Normal
Attachments: unnamed
EFTA00026686


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: DB/DFS
Date: Tue, 07 Jul 2020 18:01:48 +0000
Okay, good. Thanks.
From:
Sent: Tuesday, July 7, 2020 1:53 PM
To:
Cc:
is
Subject: RE: DB/DFS
Yeah we actually already know what it's referring to - DB did an extremely comprehensive presentation to us, and has
produced a large amount of documents. The transactions referenced include transfers we've described in both the
Epstein and Maxwell filings, among others. We had them run the names of a bunch of people for transfers - see the
attached email and its attachment - and they also did a summary chart of his accounts, also attached. And yeah it's
Parvin, she's done a really thorough job. I share your view that despite the press coverage, there doesn't appear to have
been any malfeasance at all in connection with the Epstein accounts.
From:
Sent: Tuesday, July 07, 2020 13:44
To:
>;
V.
Subject: DB/DFS
Looks like DFS settled with Deutche Bank yesterday. The press coverage is all about Epstein and the ostensibly
"suspicious" transactions they processed for him, but if I'm a betting man, I'm betting the bulk of the resolution is based
on the last sentence of the article: "The fine also covered the German bank's connection to a massive money laundering
scheme and other improper activity."
https://www.washingtonpost.com/business/2020/07/07/deutsche-bank-fined-150-million-relationship-with-jeffrey-
epstein-other-lapses/
Anyway, maybe worth seeing if you can pull the public settlement docs to see what the allegedly suspicious transactions
entailed. Or you can go straight to the bank, I suppose. Remind me, does Parvin represent them?
EFTA00027017


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=== Page 1 ===
From: BOBBI C STERNHEIM
Cc: Christian Everdell
Laura Menninger
Jeff Pagliuca
Subject: Re: US V. Maxwell - -Trial Start Date
Date: Tue, 11 May 2021 04:16:01 +0000
Attachments: Letter_re-_Trial_Start_Date.pdf; ATT00001.htm
Attached is a courtesy copy of our letter requesting 11/8 trial start date.
EFTA00024911


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: Read: RE: Question re Epstein Relativity
Date: Wed, 17 Mar 2021 13:37:40 +0000
EFTA00024026


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c6: pdf
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
,
)"
Subject: FW: Grand Jury Subpoena Issued to UBS Financial Services Inc. dated June 29, 2020
Date: Fri, 10 Jul 2020 18:08:50 +0000
Attachments: 2020.07.10-Document_Production_Cover_Letter.pdf: Document_Production.zip;
disclaim.txt
Inline-Images: image001.png; image002.png
Hi
- attached is a new batch of UBS returns, could you please add them to the shared + tracker and send to
?
Thanks! Password is 43581909-2020-1037.
From: jezebel.diaz@ubs.com <jezebel.diaz@ubs.com>
Sent: Friday, July 10, 2020 2:05 PM
To:
Cc:
nicole.canter@ubs.com;
>;
Subject: [Not Virus Scanned] [Not Virus Scanned] Grand Jury Subpoena Issued to UBS Financial Services Inc. dated June
29, 2020
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.
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.
Attached is part 1 of the document production along with our cover letter for the above referenced subpoena. The
production is password protected. The password to the production will be provided separately.
Thank you,
Jezebel
UBS
UBS
Diaz
Paralegal
Authorized Officer
UBS Group AG
Legal - Subpoenas, Levies & Garnishments
1285 Avenue of the Americas - 12th Floor
New York, NY 10019
(615) 393-7621
EFTA00024447

=== Page 2 ===
EFTA00024448


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: "Mark S. Cohen"
Christian Everdell
Laura Menninger <]
>, , "Jeff
Pagliuca"
Subject: U.S. V. Maxwell 20 Cr. 330 (AJN)
Date: Tue, 24 Nov 2020 21:00:20 +0000
Attachments: Maxwell_Reply_to_90-day_conditions_Itr.pdf; ATT00001.htm
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Best-
Bobbi
EFTA00026464


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=== Page 1 ===
90A-NY-3151227 Serial 37
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027710
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027710: One (1) Seagate
Barracuda 1000GB HDD, ST1000DM003, S/N Z1DB25CT, containing the Clone
Copy of 1B11 hard drive (Seagate Constellation ES 500GB HDD, ST500NM0011,
S/N Z1M1PX26), collected via Tableau TD3-B S/N 01D3B09E-1331. Request ID
112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027710: One (1) Seagate Barracuda 1000GB HDD,
ST1000DM003, S/N Z1DB25CT, containing the Clone Copy of
1B11 hard drive (Seagate Constellation ES 500GB HDD,
ST500NM0011, S/N Z1M1PX26), collected via Tableau TD3-B
S/N 01D3B09E-1331. Request ID 112048. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Derivative
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00025429

=== Page 2 ===
90A-NY-3151227 Serial 37
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027710
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00025430


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
"
)"
,
Cc:
)"
Subject:
302 and
phone 302
Date: Thu, 23 Apr 2020 19:48:24 +0000
Attachments: Interview_of
pdf; Interview_of
df
EFTA00025099


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: FW: Jeffrey Epstein
Date: Mon, 31 Aug 2020 22:48:07 +0000
Is it this person?
From:
(USANYS)
Sent: Friday, July 12, 2019 6:48 PM
To:
Cc:
(USANYS)
is
;
Subject: Re: Jeffrey Epstein
Thanks. Will raise up.
Sent from my iPhone
On Jul 12, 2019, at 6:24 PM,
wrote:
Below is the information that
attorney forwarded me about the State's attorney's office.
Thanks,
Sent from my iPhone
Begin forwarded message:
From:
Date: July 12, 2019 at 6:05:19 PM EDT
To:
Subject: Fwd: Jeffrey Epstein
This email was sent via my iPhone using the dictation app... Please understand there may be some typographical
or grammatical errors.
EFTA00023966

=== Page 2 ===
NOTICE: This E-mail (including attachments) is covered by the Electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, is confidential and may be ATTORNEY PRIVILEGED and CONFIDENTIAL.
It is intended only for the use of the individual or entity named as recipient. If the reader
of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication or any of its contents, is strictly prohibited.
If you have received this communication in error, please notify sender immediately by re-sending
This communication to the sender and delete the original message and any copy of it from your
computer system.
Thank you for your cooperation.
Begin forwarded message:
From:
Date: July 12, 2019 at 11:22:04 AM EDT
To:
Cc:
Subject: Jeffrey Epstein
Mr.
It was great touching base with you this morning. As I mentioned on the phone, the Office of the State Attorney is
interested in any information that could lead to criminal charges from that crimes occurred in Palm Beach County. If
you aware of any victims who would like to make a statement to local law enforcement please advise. Feel free to
pass my contact information on to anyone who might have information.
Regards-
Assistant State Attorney
Special Victim's Unit
Human Trafficking and ICAC
Office Of The State Attorney
15th Judical Circuit
Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records
available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure.
EFTA00023967


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Pretrial Motion Reply Memoranda and
Exhibits (to be Filed Under Seal)
Date: Tue, 16 Mar 2021 02:23:36 +0000
Attachments: 2021.03.15_Filing.zip
Inline-Images: image003.gif; image005.jpg; image006.jpg; image005(1).jpg; image006(1).jpg
FYI
From: Christian Everdell
Sent: Monday, March 15, 2021 10:19 PM
To: lNathanNYSDChamber
Cc:
is
is
(USANYS)
is
)
>; ; 'BOBBI C STERNHEIM'
>; 'Jeff Pagliuca'
>; 'Laura Menninger'
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Pretrial Motion Reply Memoranda and Exhibits (to be Filed Under
Seal)
Dear Judge Nathan -
As set forth in the attached cover letter and pursuant to Rule 2(B) of the Court's individual rules, attached for the Court
and government are two versions (redacted and unreacted) of Ms. Maxwell's reply memoranda in support of her pretrial
motions and accompanying exhibits. A redacted cover letter is being filed on the public docket.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00024021

=== Page 2 ===
CG
COHEN & GRESSER LLP
C&G
EFTA00024022


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=== Page 1 ===
From:
To:
Subject: draft protective order
Date: Thu, 09 Jul 2020 18:47:23 +0000
Attachments: 2020-07-03,_GM,_protective_order_for_discovery_(A.IN).docx
Team, apologies again for the delay on this (among other things - and you'll be entertained by this - I have an extremely
unexpected in-custody arrest today! on a VOSR for failure to check in with probation, with a warrant from *early
February*!!), but draft is attached. It is as strong as I could think to make it, but very happy to take additional thoughts or
suggestions, and I anticipate we'll likely get some pushback but we can see what they say. Thoughts / comments / edits?
Thanks.
EFTA00024786


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=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Tue, 09 Mar 2021 21:56:29 +0000
Inline-Images: image001.jpg
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <lmenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI c STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
EFTA00025200

=== Page 2 ===
From:
)
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007 It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
)
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00025201

=== Page 3 ===
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
EFTA00025202

=== Page 4 ===
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00025203


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=== Page 1 ===
From:
To:
Cc:
Subject: for new victim witness services website, for the Maxwell case
Date: Wed, 08 Jul 2020 15:30:46 +0000
Could we please create a new Victim & Witnesses Services page for the Maxwell case, similar to what we did for the
Epstein case last year? The header can be the same format as Epstein, with the top two lines as:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
If you believe you were a victim of Ghislaine Maxwell or have information about the allegations in the Indictment,
please call 1-800-Call-FBI
And then for the first entry, a "July 8, 2020 update", could we please post the following, along with a link to the PDF of the
indictment:
On July 2, 2020, the United States Attorney's Office announced the unsealing of federal felony charges against GHISLAINE
MAXWELL on charges of enticement of a minor to engage in illegal sex acts, transportation of a minor to engage in illegal
sex acts, conspiracy, and perjury. These crimes are alleged to have occurred in locations including, but not limited to, New
York, Florida, New Mexico, and the United Kingdom.
If you believe you are a victim of GHISLAINE MAXWELL, from during any time period and in any location, please contact
the Victim / Witness specialists at the U.S. Attorney's Office listed below.
The charges are contained in Indictment 20 Cr. 330 (AJN). You may view a copy of the Indictment here.
Updates regarding the progress of this case will be posted on this site.
The United States Attorney's Office for the Southern District of New York is committed to protecting the rights of crime
victims. If you believe you are a victim of the offense charged, our Victim/Witness Unit can make sure that you are
notified of important stages of the case to help you exercise your rights. In addition, our Victim/Witness Unit can help
refer you to agencies that provide other services to witnesses, such as compensation (under certain circumstances) and
counseling. If you believe you are a victim, of if you would like information or assistance with referrals, please contact:
Victim/Witness Coordinator
United States Attorney's Office
New York, New York 10007
*
*
*
Let us know if any questions or issues at all? And thanks very much as always.
EFTA00024440

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00024441


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=== Page 1 ===
From:
"
"
To:
)"
(NY) (FBI)"
Cc:
"
)"
(USANYS)"
Subject: Re:
Date: Thu, 08 Oct 2020 20:38:03 +0000
Attachments: (U)
;
pdf
See attached:
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Thursday, October 8, 2020 4:29 PM
To:
is
;
(NY) (FBI)
Cc:
is
;
(USANYS)
Subject:
Hi
and
Could you please send us the notes and 302 from the most recent interview of
?
Thanks,
EFTA00026811


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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: Re:
Date: Mon, 23 Nov 2020 16:32:43 +0000
Embedded: Re:
.msg
Sender:
Subject: Re
Message-Id: <B6976009-423C-4DBF-B473-069017769D4F@usa.doj.gov>
To:
Cc:
Cc:
Cc:
Cc:
EFTA00026463


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
)"
Bcc: "USAHUB-USAJournal111"
Subject: FW: Hard drive copy
Date: Tue, 13 Oct 2020 14:24:25 +0000
Embedded: FW:_Hard_drive_copy.msg
Sender:
Subject: FW: Hard drive copy
Message-Id:
<CY1P110MB048787AE2998F0681921183CE3040@CY1P110MB0487.NAMP110.PROD.OUTLOOK.COM>
To:
EFTA00025389


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: Conflict Sweep: Debevoise & Plimpton; Lankler Siffert & Wohl
Date: Tue, 07 Jul 2020 17:02:00 +0000
Matter involving Debevoise & Plimpton:
USAONo: 2018R01618
Docket No: 19 Cr. 490 / 20 Cr. 330
Summary: Investigation of Jeffrey Epstein and prosecution of Ghislaine Maxwell
Role of Debevoise: Represents
a subject / witness in the Epstein investigation
I believe that
already got a waiver on this, but sending in an abundance of caution.
From:
(USANYS)
Sent: Tuesday, July 07, 2020 11:48
To:
is
Subject: Conflict Sweep: Debevoise & Plimpton; Lankler Siffert & Wohl
For any active case or matter involving either Debevoise & Plimpton, or Lankler Siffert & Wohl, * please advise
me:
USAONo:
Docket No (if any):
Brief summary of case and status:
Role of Debevoise or Lankler in the case:
*If you have already communicated with me about a case involving LSW, you don't need to give me the
information again.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
(desk)
(mobile)
EFTA00026998


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
)"
Subject: Letter to AJN
Date: Tue, 17 Aug 2021 23:32:34 +0000
Attachments:2021.08.13_AJN_opinion_-_supplemental_pretrial_motions.pdf;2021-08-
17_GM_letter_to_AJN_re_co-conspirator_identities.docx
Hey
As you may have seen, on Friday, Judge Nathan denied all of Maxwell's supplemental motions. (She also denied an ex
parte motion for some Rule 17 subpoenas, so it seems like our earlier motion was effective.)
Judge Nathan's order, however, says that we did not object to providing the defense with the identities of Maxwell's
uncharged co-conspirators, and she presumes we intend to do so.
We've drafted the attached letter explaining that we do not, in fact, intend to do so. For convenience, Judge Nathan's
opinion is attached, and the relevant passage is footnote 1 on page 12.
Thanks,
Andrew
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00023894


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=== Page 1 ===
From:
To: Jordan Merson
Cc: Matthew Merson
Jesse Mautner
Colleen Carlo
Subject: RE: SDNY criminal investigation
Date: Thu, 09 Jan 2020 22:15:57 +0000
Jordan,
Thank you again for speaking with me yesterday, and as I mentioned, my two colleagues on the Epstein investigation are
and
both copied here-please feel free to be in touch with any or all of us anytime that
would be useful. As I mentioned, we would be interested in learning the accounts of your clients, and we would-as we
have with all the victims we've spoken to so far-engage with them with the highest levels of sensitivity, including there
being no requirement to discuss any particular event or topic at any time. Even to the extent there are any individuals
who would not currently be comfortable speaking with us directly, if they would permit you to provide an attorney proffer
to us, that also could be very helpful.
And in the first instance, to the extent this is possible, it would be very helpful for us just to be provided the names of your
clients-we would not attempt to contact them outside of our discussions with you, but knowing who they are will help
us inadvertently approaching individuals who are in fact represented, and would also help us identify to you any particular
individual(s) who might be known to us already.
We look forward to being in touch with you soon, and thank you again for being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Jordan Merson
Sent: Wednesday, January 08, 2020 15:34
To: Colleen Carlo
is
Cc: Matthew Merson
>; Jesse Mautner
Subject: Re: SDNY criminal investigation
Good speaking with you. We will relay our discussion to our clients and see if there is interest. Is there any
timeline that we should be aware of
Sent from my iPhone
On Jan 8, 2020, at 11:50, Colleen Carlo
wrote:
EFTA00026547

=== Page 2 ===
Forwarded message
From:
Date: Wed, Jan 8, 2020 at 11:45 AM
Subject: RE: SDNY criminal investigation
To:
Good morning,
I am a federal prosecutor with the Southern District of New York, and I have been trying to reach Mr. Merson; I
left phone messages last Monday and Thursday and also earlier this morning. I am interested in speaking with
Mr. Merson regarding our Office's ongoing investigation into conduct relating to Jeffrey Epstein. I would
appreciate a response from Mr. Merson or any appropriate person.
Regards,
Assistant U.S. Attorney
Southern District of New York
Colleen Carlo
Office Manager
Merson Law PLLC
Tel:
Fax:
CONFIDENTIALITY NOTICE:
This message is a PRIVATE COMMUNICATION. This message and all attachments are a private
communication sent by Merson Law, PLLC, and are confidential and/or protected by privilege. If you are not
the intended recipient, you are hereby notified that any disclosure, copying, distribution or any use of the
information contained in or attached to this message is strictly prohibited. Please notify the sender of your
receipt of this message in error by replying to this message upon receipt. Thereafter, you are required to delete
any and all copies of this message and any attachment and return any hard copies of the materials contained
therein to the sender. The receipt in error of this message and any attachment is not a waiver of the various
privilege(s) attached to this communication.
EFTA00026548


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=== Page 1 ===
From:
To:
Cc:
Subject: [EXTERNAL] information
Date: Mon, 25 Oct 2021 16:40:03 +0000
Hi,
Hope this finds you well.
I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request regarding
my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
Scanned by McAfee and confirmed virus-free.
EFTA00025033


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=== Page 1 ===
From: Roberta Kaplan
To:
)"
Conlon"
Jenna Dabbs
Alexandra Elenowitz-
Hess
Cc:
)"
)"
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 02:06:10 +0000
Can you talk?
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
New York, New York 10118
From:
)
Sent: Wednesday, July 10, 2019 5:56:39 PM
To:
Conlon; Roberta Kaplan; Jenna Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has the
right to be reasonably heard at certain public proceedings in the district court, including proceedings involving release.
Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's rights-under
that statute, to see whether your client would like to be heard in any fashion, whether through a submission, a
representation that we can include in our bail submission due Friday, or some other form. Of course no requirement or
obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make myself
available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
EFTA00026681

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify the
sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00026682


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=== Page 1 ===
Event: Accepted: Epstein bail hearing
Start Date: 2019-07-15 14:00:00 +0000
End Date: 2019-07-15 14:30:00 +0000
Organizer:
)
Location: 17B (Berman)
Class: X-PERSONAL
Comment:
Date Created: 2019-07-10 05:55:53 +0000
Date Modified: 2019-07-10 05:55:53 +0000
Priority: 5
DTSTAMP: 2019-07-10 05:50:32 +0000
EFTA00026650


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
(USANYS)"
,
(USANYS)"
i
(USANYS)"
Cc:
"
)"
(USANYS)"
,
)"
Bcc: "USAHUB-USAJournal111"
Subject: Opposition to Maxwell GJ Motion
Date: Mon, 22 Feb 2021 21:01:15 +0000
Embedded: Opposition_to_Maxwell_GJ_Motion.msg
Sender:
Subject: Opposition to Maxwell GJ Motion
Message-Id:
<BN3P110MB03391D6831C279177A194AF192819@BN3P110MB0339.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
To:
Cc:
Cc:
Cc:
EFTA00026596


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c0:
=== Page 1 ===
From:
)"
To: Sigrid McCawley
Cc:
)"
Subject: RE:
follow-up request
Date: Thu, 07 May 2020 22:40:59 +0000
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day -whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
EFTA00025324

=== Page 2 ===
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
;
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
EFTA00025325

=== Page 3 ===
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
i
)
Subject: RE:
follow-up request
Hello
,
EFTA00025326

=== Page 4 ===
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
)
Subject:
follow-up request
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
EFTA00025327

=== Page 5 ===
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00025328


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=== Page 1 ===
From: Christian Everdell
To:
)"
Cc: "Mark S. Cohen
)"
)"
Subject: RE: Pretrial Interview - Ghislaine Maxwell
Date: Mon, 06 Jul 2020 17:46:26 +0000
H
You can reach me at
and Mark at
We look forward to hearing from you.
Regards,
Chris
From
Sent: Monday, July 06, 2020 1:36 PM
To
)
Cc: Christian Everdell; Mark S. Cohen;
)
Subject: Re: Pretrial Interview - Ghislaine Maxwell
Chris and Mark-
I will be in touch this evening with you.
Please provide me with the best contact number.
Thanks
U.S. Pretrial Services
On Jul 6, 2020, at 1:33 PM,
wrote:
Good afternoon,
Copied on this email are Chris Everdell and Mark Cohen, two attorneys representing defendant Ghislaine Maxwell in
case number 20 Cr. 330 (AJN). Please let them know how they can arrange for a pretrial interview with their client in
advance of her bail hearing this week.
If you need any additional information, please do not hesitate to contact me.
Thank you,
Assistant United States Attorney
EFTA00024564

=== Page 2 ===
Southern District of New York
New York, NY 10007
EFTA00024565


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=== Page 1 ===
From:
To:
Subject:
proffer (re abuse)
Date: Wed, 04 Dec 2019 17:26:24 +0000
Importance: Normal
Attachments: unnamed
EFTA00025122


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=== Page 1 ===
From:
To: "Weinstein, Marc A."
Cc: "Tomback, Andrew"
Subject: RE: Epstein estate subpoenas
Date: Fri, 01 Nov 2019 20:41:20 +0000
Sure - we'll call you in just a moment.
From: Weinstein, Marc A.
Sent: Friday, November 01, 2019 16:39
To:
is
;
Cc: Tomback, Andrew
Subject: Epstein estate subpoenas
Are any of you available for a quick chat? I'm preparing to send you the documents we discussed shortly, but we'd like to
give you a heads up on something first.
Thanks,
Marc
Marc A. Weinstein Partner
Co-Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00024303


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
Subject: MCC Letter
Date: Fri, 06 Mar 2020 17:03:40 +0000
Attachments: Re_AP_Exclusive_loaded_gun_found_in_jail_where_Epstein_killed_himselfjpeg
Just FYSA.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00025543


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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Memo Endorsement
Date: Wed, 18 Nov 2020 20:16:24 +0000
Embedded: FW:_Activity_in_Case_1:20-cr-00330-AJN_USA_v_Maxwell_Memo_Endorsement.msg
Sender:
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Memo Endorsement
Message-Id: <644ebed3ac1a4af8beb44230d86811e0@SN1P110MB0205.NAMP110.PROD.OUTLOOK.COM>
To:
To:
To:
EFTA00026456


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: EOUSA-2020-003382, ABC News follow up
Date: Thu, 30 Jul 2020 23:04:13 +0000
Thanks,
can take it from here
Associate U.S. Attorney
Southern District of New York
On Jul 30, 2020, at 6:43 PM,
wrote:
Hi
,
I'm copying
who I understand is coordinating all responses to FOIA requests related to Jeffrey
Epstein.
The requested records are grand jury materials, and therefore covered by Rule 6(e).
Thanks,
Sent from my iPhone
On Jul 30, 2020, at 6:02 PM,
wrote:
Good evening
and
,
I am checking back in with you regarding my 2020-07-07 message about an exemption memo
for this FOIA request. Please take a look.
I am ready to assist you any way you need.
Thanks,
FOIA Officer
USAO/SDNYNYS
EFTA00026487

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, July 7, 2020 16:17
To:
>;
Cc:
Subject: EOUSA-2020-003382, ABC News
Good afternoon,
Here is a new FOIA request regarding United States V. Jeffrey Epstein. I am attaching a
standard exemption document for you. Please try to send it back on or about July 14th, 2020.
The requester entered his request directly into the portal rather than a PDF.:
"Dear records officer, Pursuant to FOIA, I request a copy of the 5 years of banking records of
Jeffrey Epstein from "Insitution-1" referenced by SDNY in a Jul 12, 2019 letter to Richard
Berman (see Page 11 of supporting document). Please acknowledge receipt of this request.
Thank you. Exact Source: Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19"
Thank you!
<EXEMPTION MEMO.docx>
EFTA00026488


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=== Page 1 ===
From
NY) (FBI)"
To:
(USANYS)"
Subject:
Date: Tue, 14 Jul 2020 18:50:32 +0000
Attachments: Initial_Review_of_Records.pdf
Hey
When looking through my case file, this is where
documented the phone number and last call made by
Epstein. Let me know if you need anything else,
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00024475


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=== Page 1 ===
From:
)"
To:
)"
Subject: Fwd: Discovery questions
Date: Thu, 20 Aug 2020 22:26:51 +0000
The box is on the back table in my office.
Sent from my iPhone
Begin forwarded message:
From:
"
) (FBI)"
Date: August 20, 2020 at 6:16:56 PM EDT
To:
)"
)"
Cc:
)"
=
(USANYS)"
Subject: RE: Discovery questions
Hey all,
Just wanted to send a quick email to detail what is being given today. There is a box of media, including VHS, cassette,
and microcassettes, and newspaper articles that were provided by Reiter.
On the thumbdrive is a spreadsheet outlining what is included; items highlighted in blue are included. You will notice a
comment "see disk tracking spreadsheet" in items not highlighted; this spreadsheet will be included in the disk copies
we send over that will detail how many images total and how many removed.
There are loose disks which include 1B evidence scans, 1D1-1D5 evidence items, LSJ 3D imaging, and the FBI file.
Separately, we will keep you updated as we continue to work on the redactions and will let you know as soon as we
finish with the disks.
Let us know you have any questions.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
From:
Sent: Wednesday, August 19, 2020 8:43 PM
To:
)
Cc:
) (FBI)
is
is
EFTA00026741

=== Page 2 ===
is
(USANYS)
Subject: [EXTERNAL EMAIL] - Re: Discovery questions
I'll be in the office tomorrow.
Sent from my iPhone
On Aug 19, 2020, at 8:18 PM,
)
wrote:
Great, thanks very much. I'm not in the office right now, but hopefully someone from the team can grab these. If not,
I can find a paralegal to take them.
From:
(FBI)
Sent: Wednesday, August 19, 2020 7:24 PM
To:
is
is
)
Cc:
V.
(USANYS)
Subject: RE: Discovery questions
Sure no problem. I can bring those over tomorrow as well.
From:
Sent: Wednesday, August 19, 2020 7:22 PM
To:
) (FBI)
is
is
)
Cc:
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Perfect, thanks! Yes, I think we should take the vhs tapes and microcassettes to get them converted, if that's ok.
From:
(FBI)
Sent: Wednesday, August 19, 2020 7:20 PM
To:
is
is
)
Cc:
>;
(USANYS)
Subject: RE: Discovery questions
That sounds great. Thank you. We are definitely open to them scheduling a time if need be.
I will check in with CART again and get back to you.
As far as the paper evidence and case file, we can drop that off to your office sometime tomorrow evening. Just
working on putting it all on a disk/thumbdrive for you. Also, FYI, included in the boxes from Reiter are vhs tapes and
microcassettes. Would you like us to turn these over to you as well? Let me know your thoughts on this.
Thanks!
From:
Sent: Wednesday, August 19, 2020 7:01 PM
To:
) (FBI)
is
is
)
EFTA00026742

=== Page 3 ===
Cc:
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thank you so much for these-very helpful (and sorry I didn't realize the message pad scans also had the same pages
without post-its!)
On these:
Yes, please send over the copy of the gj transcript disc when you can.
Found the original scans from the FL file-thank you!
Yes, please get us the paper evidence from NY, VI, and Reiter as soon as you can.
We'll take the FBI file whenever you can get it to our office.
My understanding from past FBI cases is that CART completes some sort of paperwork documenting the dates
on which they conduct data extractions. We need that for all of the extractions in this case, please (It may not
be 302s).
On the evidence from disks, understood. In order to give you more time, we are going to tell the defense
attorneys that the materials are available for them to review in-person if they want to schedule a time to come
down to the FBI office, but that in the meantime we are still working on getting copies of non-nude images to
produce to them.
From:
) (FBI)
Sent: Wednesday, August 19, 2020 2:21 PM
To:
is
is
)
Cc:
is
(USANYS)
Subject: RE: Discovery questions
Hey all, below is a summary of the discovery items you've requested.
Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the
page without the post it note, so the pages are back to back.
Papers from Miami case file (grand jury testimony): This is a disk - I can copy it and send it over to you.
Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad
scans last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence
from the NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.
FBI file: We have that ready for you.
CART: There are no 302s regarding the extraction of devices.
Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images.
This is the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this
together, that would be very helpful.
EFTA00026743

=== Page 4 ===
If it's helpful to talk through some of this via phone, we are happy to do that as well.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
From:
Sent: Tuesday, August 18, 2020 6:41 PM
To:
>;
Cc:
) (FBI)
i
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thanks so much,
Really appreciate all the work you and
are putting in on this. Let's touch base tomorrow
to figure out the timeline for the discovery issues.
From:
Sent: Tuesday, August 18, 2020 6:40 PM
To:
>;
)
Cc:
) (FBI)
is
>;
(USANYS)
Subject: Re: Discovery questions
Hey guys,
Apologies but today I was out In the field on surveillance and
was also out of the office so we've not
been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into
this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best
to get on this list. That being said I don't want to make you any promises that everything will be compiled by
tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if
you like to square some of this away.
I did receive your "pages from Miami_case_docs" PDF.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
EFTA00026744

=== Page 5 ===
Cell:
Fax:
From:
Sent: Tuesday, August 18, 2020 6:03 PM
To:
is
Cc:
) (FBI)
is
is
(USANYS)
Subject: RE: Discovery questions
Hi
and
Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these
materials tomorrow or Thursday?
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:41 PM
To:
is
Cc:
) (FBI)
is
is
(USANYS)
Subject: RE: Discovery questions
Hi
and
The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a
larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to
provide us with all of those scans this week?
With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes
on them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:45 AM
To:
Cc:
) (FBI)
is
)
is
is
(USANYS)
Subject: RE: Discovery questions
Sorry, got a bounceback for
too. I'm just attaching the one page I referenced in my email below. Hopefully that
will go through.
From:
Sent: Tuesday, August 18, 2020 4:40 AM
To:
Cc:
) (FBI)
is
)
is
EFTA00026745

=== Page 6 ===
(USANYS)
Subject: FW: Discovery questions
I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went
through for
so she can see it. If not, please let me know.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:33 AM
To:
is
) (FBI)
Cc:
is
(USANYS)
Subject: Discovery questions
Hi
and
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most
recent batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery
dropped off a few days ago with requests for additional items:
The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
The message pad scans you provided still have post-it notes on top of several of the message pad pages. I
think
mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-
and those copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the
"Message pad scans" folder. Would you please get us a scans of these without post-its on them?
It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant.
Would you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
Full FBI sentinel file
CART paperwork regarding the extraction of data from all devices seized during the investigation
All 302s regarding the extraction of data from any seized devices and the review of images (both digital and
hard copy) seized during the investigation, including from Epstein's properties.
Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been
scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any
nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how
many such images were scanned, where they were from, and where they are being stored.
Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a
platform for review. Then please produce to SDNY a copy all of those materials, except any nude or partially
nude images. For nude or partially nude images, please provide us with a log detailing how many such images
were located, where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
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=== Page 7 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026747


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=== Page 1 ===
Event: Epstein FOIA Moot
Start Date: 2021-04-07 20:00:00 +0000
End Date: 2021-04-07 20:30:00 +0000
Organizer:
Location:
Class: X-PERSONAL
Date Created: 2021-03-26 19:38:14 +0000
Date Modified: 2021-03-26 19:38:14 +0000
Priority: 5
DTSTAMP: 2021-03-26 19:15:16 +0000
Attendee:
Alarm: Display the following message 15m before start
I
Reminder
EFTA00024014


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=== Page 1 ===
From:
To:
Subject: FW: Emailing:
0190821161745994_DRAFT.pdf
Date: Wed, 21 Aug 2019 20:20:39 +0000
Attachments:
20190821161745994_DRAFT.pdf
Are you guys ok with this going out?
From:
Sent: Wednesday. August 21. 2019 4:18 PM
To:
Subject: Emailing:
0190821161745994_DRAFT.pdf
EFTA00024409


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: RE: 17(c) letter
Date: Thu, 18 Nov 2021 13:22:34 +0000
Attachments: 2021.11.18_Mot_to_quash.agm.docx
Thanks! Some things in track.
From:
Sent: Wednesday, November 17, 2021 11:57 PM
To:
(USANYS)
is
)
is
Subject: 17(c) letter
Hi all,
17(c) letter attached. If nobody has a minute to skim or read this between now and voir dire-which is my guess, given
the timing-I'll just send to
at 8:30.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: Point of View: Jeffrey Epstein victims not silenced by NDAs, attorney says - Opinion - The
Palm Beach Post - West Palm Beach, FL
Date: Sun, 30 Jun 2019 22:35:55 +0000
Importance: Normal
I know you guys have google alerts, too, but I thought it was interesting that Brad wrote this, given everything
that's going on.
https://www.palmbeachpost.com/opinion/20190630/point-of-view-jeffrey-epstein-victims-not-silenced-by-ndas-
attorney-says
Sent from my iPhone
EFTA00026665


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=== Page 1 ===
Victim Services Division Documentation of Services
Download Date: 14-AUG-20
From: 01-JAN-00
To: 14-AUG-20
Victim Name:
FBI Case Number:
Downloaded By:
Service Type
Number of Services
Crisis Intervention
1
Follow Up Contact In Person
1
Follow Up Contact Phone Call
2
Follow Up Contact Text
4
Initial Contact Text
1
Other
1
Resource / Referral Provided Counseling / MH Provider
2
Additional Notes and Services:
*This document will become a permanent record in the case file and is discoverable. Please limit comments to logistical or service referral information. Do not reference
mental health information or personal opinion.
1
EFTA00025006

=== Page 2 ===
2
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=== Page 1 ===
From:
"
(USANYS)"
To: "
(USANYS)"
Cc: "
(USANYS)"
Subject: PC Updates
Date: Fri, 02 Oct 2020 20:40:57 +0000
Attachments:PC_Unit_-Short_Form_Update.10.2.20.docx
- See attached.
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00026572


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=== Page 1 ===
From:
=
(NY) (FBI)"
To:
)"
Subject: spreadsheet
Date: Tue, 14 Jul 2020 20:09:02 +0000
Attachments: EpsteinNYEvidence.xlsx
Here you go. Almost everything is over at Southern once I drop off the phones. Just I laptop and 2 desktops to get to you. I has to
re-process, so I am not sure how long it will be as it is a large item. As far as the stuff I have already produced, I can re-work it to split
things out, but unsure how much static it will give me. Might be fast, might be a pain. Unknown at this point, but I am sure we can get
something moving. Any questions, let me know.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
(USANYS) [Contractor]"
Cc:
(USANYS)"
Subject: RE: discovery
Date: Thu, 28 Oct 2021 14:33:52 +0000
Added, thanks!
From:
Sent: Wednesday, October 27, 2021 11:15 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
^
Cc:
(USANYS)
Subject: discovery
Hi team,
Could you please add the materials saved here to the next production? Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00025159


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=== Page 1 ===
From:
)"
To:
(NYPD)"
Cc:
(NY) (FBI)"
(USANYS)"
Subject: Application for corrected SW
Date: Fri, 23 Oct 2020 00:44:08 +0000
Attachments: Application_for_Amended_Warrant_for_3_Drives_from_NY_Residence_v2.docx:
Exhibit_A-_July_11,_2019_Warrant.pdf,Exhibit_B_- -
_Application_for_June_2020_Warrant.pdf; Exhibit C - June_2020_Warrant.pdf;
Exhibit_D_-_Maxwell_Superseding_Indictment_-_S1_20_Cr_330_(AJN)_(docketed).pdf
As discussed earlier today, attached please find a draft affidavit in support of an amended warrant for three of the drives
seized from Epstein's NY residence. I'm also attaching the four exhibits referenced in the affidavit.
Please review this closely and let me know if you have any questions or revisions at all. I'll reach out to you on Monday to
talk about when it makes sense to schedule a time to swear this out.
Thanks,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: "john@raymitevlaw.com" <john@raymitevlaw.com>
Cc:
)"
)"
Subject: RE: Epstein investigation
Date: Fri, 27 Mar 2020 20:38:22 +0000
John,
Wanted to get back to you regarding your letter of March 9, 2020, which we received via the Eastern District U.S.
Attorney's Office, and your follow-up call this week, both of which we appreciate. We did receive the letter, and in the
first instance it would be helpful to know the name and contact info of the person who's the source of this information
(assuming it is someone other than you) - we ordinarily pass this kind of information to the FBI for initial response, but it's
not clear from the letter whom they would be in touch with to follow up. It would also be helpful to know, if you're
aware, whether there is any allegation that the relevant interns were underage.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
ACTING U.S. ATTORNEY AUDREY STRAUSS
FOR IMMEDIATE RELEASE
CONTACT: U.S. ATTORNEY'S OFFICE
Thursday, July 2, 2020
http://www.justice.gov/usao/nys
FBI
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT
FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE
MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New
York, William F. Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of
the Federal Bureau of Investigation ("FBI"), and Dermot Shea, Commissioner of the New York
City Police Department ("NYPD"), announced that GHISLANE MAXWELL was arrested this
morning and charged with enticing a minor to travel to engage in criminal sexual activity,
transporting a minor with the intent to engage in criminal sexual activity, conspiracy to commit
both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-
conspirator Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel
and transporting them for the purpose of engaging in illegal sex acts. As alleged, knowing that
Epstein had a preference for young girls, MAXWELL played a critical role in the grooming and
abuse of minor victims that took place in locations including New York, Florida, and New
Mexico. In addition, as alleged, MAXWELL made several false statements in sworn depositions
in 2016. MAXWELL is expected to be presented this afternoon in the in federal court in New
Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated,
aided, and participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them
to trust her, and then delivered them into the trap that she and Jeffrey Epstein had set. She
pretended to be a woman they could trust. All the while, she was setting them up to be abused
EFTA00024556

=== Page 2 ===
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 Indictment¹ 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.
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.
2
EFTA00024557

=== Page 3 ===
MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with
victims, encouraging them to massage Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims
vulnerable and susceptible to sexual abuse by Epstein. MAXWELL was then present for certain
sexual encounters between minor victims and Epstein, such as interactions where a minor victim
was undressed, and ultimately MAXWELL was present for sex acts perpetrated by Epstein on
minor victims. That abuse included sexualized massages during which a minor victim was fully
or partially nude, as well as group sexualized massages of Epstein involving a minor victim
where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other
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
###
3
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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
,
)"
Subject: Opening
Date: Fri, 19 Nov 2021 00:44:13 +0000
Attachments: Maxwell_Opening_v5.docx
Hi team,
Attaching an updated draft of the opening reflecting comments from
and
I played around with the structure of
the pyramid scheme; let me know what you think. I left in a few comments I am hoping we could quickly discuss
tomorrow.
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:
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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
)"
(USANYS)"
Cc:
(NYPD)"
Subject: Other documentation
Date: Tue, 12 Jan 2021 17:43:21 +0000
Attachments: (U)_Documentation_of_services.pdf;
(U)_Documentation_of_Services_by
04_01_2020-06_30_2020.pdf;
(U)_S-00099701-A-011.pdf.pdf; (U)_Victim_Services_Division_-
_Case_Support_Unit_Assistance.pdf
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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
October 26, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing witness materials and discovery pertinent to Ghislaine
Maxwell (02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by
Assistant United States Attorneys
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=== Page 1 ===
From:
To: Sigrid McCawley
Cc:
Subject: RE: Epstein investigation
(
Date: Tue, 03 Mar 2020 22:19:09 +0000
Thanks very much.
From: Sigrid McCawley
Sent: Tuesday, March 3, 2020 5:18 PM
To:
Cc:
is
Subject: RE: Epstein investigation
(
Yes. We will be there at 2:00 for the interview. Thanks.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From:
[mailto:
Sent: Tuesday, March 3, 2020 5:15 PM
To: Sigrid McCawley
>
Cc:
is
Subject: RE: Epstein investigation
(
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
Hi Sigrid,
Just confirming our meeting tomorrow - does 2 p.m. still work for you?
Thanks very much,
From: Sigrid McCawley
Sent: Tuesday, February 25, 2020 11:49 AM
EFTA00025125

=== Page 2 ===
To:
Cc:
is
Subject: RE: Epstein investigation
(
Very helpful - thanks.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
(
www.bsfllp.com
From:
Sent: Tuesday, February 25, 2020 11:43 AM
To: Sigrid McCawley
Cc:
Subject: Re: Epstein investigation
(
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Sigrid,
That works for us, thanks very much - we'll plan for 2:00 on the 4th.
And the street address is 1 St. Andrews Plaza, though for purposes of using Google Maps, it's often easier to get directions
to 5 Centre Street if you let her know the building is through an archway and just to the left of a very large outdoor red
sculpture. And of course she should feel free to calm us if she needs any assistance with directions or transportation.
Thanks,
On Feb 25, 2020, at 09:03, Sigrid McCawley
wrote:
Hello
I spoke to
and she and I can meet with you on Wednesday, March 4th at 2:00 p.m. Please confirm that works
for your team. Can you also please send me the street address for your building so I can get that to
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00025126

=== Page 3 ===
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From:
Sent: Monday, February 24, 2020 4:45 PM
To: Sigrid McCawley
Cc:
Subject: RE: Epstein investigation
(
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Sigrid,
Thank you again for speaking with us this afternoon, we appreciate it. As discussed, we wanted to follow up with you
via email about a possible meeting with Ms.
-it sounded like it might be convenient to do a meeting next
week while you're in New York, if that would work for her? If so, if you could give us the dates and time ranges that
might be possible, we can coordinate on scheduling on our end as well. And of course as always we're happy to address
any questions that you or she might have in advance.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00025127


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=== Page 1 ===
U.S. Department of Justice
Federal Bureau of Prisons
March 5, 2020
Contact: Office of Public Affairs
202-514-6551
Bureau of Prisons Statement on MCC New York
On Thursday February 27th. the Bureau of Prisons received critical information that a firearm may
have been introduced into the Metropolitan Correctional Center (MCC) New York, New York.
Bureau of Prisons (BOP) immediately placed the facility on modified operations status in order to
protect the public, staff, and inmates until a comprehensive search could be completed.
Over the past week, as a result of the security procedures and protocols put in place, the BOP
investigative teams recovered numerous contraband items to include cell phones, narcotics and
home-made weapons. All of these items pose a significant threat to the safety and security of the
facility as well as the public.
On Thursday March 5th, BOP staff located a loaded firearm in one of the housing units. The
facility will continue to remain on modified operations status to finalize searches in all areas of the
facility.
The BOP provided an update to the Office of Inspector General and Federal Bureau of
Investigation. The BOP is committed to the safety of staff, inmates and the public while
continuing to ensure that those responsible for misconduct and criminal activity are held
accountable. Requests for submissions do not constitute a Request for Proposal (RFP) or a
promise to issue an RFP in the future. Should an RFP be issued in the future, it will be posted
publicly.
Additional information about the Federal Bureau of Prisons can be found at www.bop.gov.
###


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=== Page 1 ===
From:
To:
Subject: Accepted: Call with Osborn (Epstein)
Date: Thu, 31 Oct 2019 13:41:55 +0000
Importance: Normal
Attachments: unnamed
EFTA00024304


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=== Page 1 ===
From: Trials Law360 <news-alt@law360.com
To:
Subject: Judge Scolds Lawyer At Walmart Trial & Nazi-Looted Art Case Gets Day In Court
Date: Wed, 05 Dec 2018 09:59:22 +0000
Law360 Trials
TRIALS
The Data-Driven Lawyer
Meet the 2018 award winners and get insights into their innovative practices.
Wednesday, December 5, 2018
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
'I Am Not Co-Plaintiff Counsel,' Judge Scolds At Walmart Trial
Counsel for a class of Walmart workers seeking more than $200 million for
missed meal breaks and incomplete pay stubs was chastised by U.S. District
Judge Lucy Koh at the end of a bench trial Tuesday for asking her to look for
evidence in the record, at one point snapping, "I am not co-plaintiff counsel."
Read full article
Epstein Ducks Victim Testimony With Eve-Of-Trial Settlement
Convicted billionaire sex offender Jeffrey Epstein on Tuesday settled a
dispute with the attorney who represented his teenage victims, avoiding a
trial that was to have featured testimony from the women. Read full article »
FDIC Staffer 'Accidentally' Took Bank Secrets, Jury Told
Listen to our new podcast here
Federal prosecutors and a lawyer for ex-FDIC employee Allison Aytes gave a
LAW FIRMS
Brooklyn jury competing narratives Tuesday about what drove Aytes to make
copies of secret regulatory records before quitting, the feds saying she used
Alexander Dubose
them for job interviews and Aytes saying she accidentally swept them up with
Arnold & Itkin
other personal files. Read full article »
Baker Botts
Baker McKenzie
6 NECC Workers Had Role In Drug Fraud, Feds Say In Closing
Boies Schiller
Prosecutors on Tuesday urged a jury after seven weeks of testimony to
convict six former employees of the Massachusetts compounding pharmacy
Brown & Crouppen
whose steroids sparked a deadly meningitis outbreak in 2012, saying they
Carlton Fields
participated in a scheme to defraud federal regulators and ship out unsafe
Cole Scott
drugs to medical facilities around the country. Read full article »
Dechert
Jewish Family Seeking Art Stolen By Nazis Gets Day In Court
DiMuroGinsberg PC
The family of a Jewish woman who surrendered an Impressionist painting for
Doll Amir
her freedom from Nazi Germany told a California federal judge at a bench
Duane Morris
trial Tuesday that the masterpiece that has hung in a Spanish museum for
Ewell Brown
the past 25 years rightfully belongs to the woman's descendants. Read full
article
Fox Rothschild
Friday & Cox
Atty Tells Jury CrossFit's Sloppiness Caused Her Slipped Disc
Gibson Dunn
An attorney who specializes in personal injury work suffered a herniated disc
Greenberg Traurig
because CrossFit Inc.'s shoddy training led a local St. Louis affiliate to rush
Holland & Knight
Horack Talley
EFTA00026451

=== Page 2 ===
her into lifting too much weight on her first class, her counsel told a Missouri
Jackson Lewis
jury during Tuesday opening statements. Read full article
Jomarron Lopez
SERIES SPOTLIGHT
K&L Gates
Kendall Brill
Data-Driven Lawyer: Littler's Scott Forman
Kirkland & Ellis
Littler Mendelson PC shareholder Scott Forman's innovative case
management platform helps his firm analyze litigation data, craft defense
Kramer Levin
strategies, predict outcomes and greatly reduce client costs, earning him a
Krieger Kim
spot on our 2018 list of Data-Driven Lawyers. Read full article
Link & Rockenbach
WHITE COLLAR
Littler Mendelson
McDermott Will
NY Jury To Weigh Bribery Charges Against Hong Kong Doc
Moore & Associates LLP
A Manhattan jury was on track Tuesday to begin deliberating bribery and
Morgan Lewis
money laundering charges against a Hong Kong doctor accused of boxing up
Murphy & King
$2 million in cash for the president of Chad to facilitate an oilfield investment
Nixon Peabody
on behalf of a Chinese energy giant. Read full article
Reese Marketos
2nd Circ. Nixes $8.9M Restitution From Gambler Billy Walters
Scheper Kim
A Second Circuit panel on Tuesday vacated and remanded back to trial $8.89
Searcy Denney
million in restitution ordered against professional sports gambler Billy Walters
Shapiro Arato
for insider trading. Read full article
Shipley Snell
INSURANCE
Squire Patton Boggs
Stubbs Alderton
Progressive Settles $23M Bad Faith Case As Trial Nears
Tucker Ellis
Progressive and the family of a child hit by a policyholder's car announced a
Weinberg Wheeler
settlement Tuesday in Florida federal court in a case accusing the insurer of
Zaytoun Law Firm
exposing the policyholder to a $22.7 million judgment by failing to coax him to
complete critical paperwork. Read full article
COMPANIES
PERSONAL INJURY & MEDICAL MALPRACTICE
Altman Weil Inc.
American Cancer Society Inc.
NC Court Slashes $6.5M Jury Award In Patient Death Suit
Bass Pro Shops
A North Carolina appeals court on Tuesday vacated the bulk of a $6.5 million
Burford Capital LLC
judgment in a suit accusing a hospital of negligently treating a chest pain
Cabela's Inc.
patient, which caused his death the same day, saying the jury should not
California Teachers Association
have been allowed to award for pain and suffering. Read full article
Carolinas HealthCare System
Pa. Justices Snub Appeal Over Jury's Role In Tree Fall Case
Chicago Bulls
Pennsylvania's highest court said Tuesday that it would not hear an appeal of
Citizens for Responsibility and
a decision that jurors be allowed to consider whether a man's misuse of a
Ethics in Washington
safety harness that broke and sent him falling from a tree canceled out
Counsel on Call Services Inc.
claims that the product came with faulty warnings and instructions. Read full
CrossFit Inc.
article
Deutsche Bank AG
COMMERCIAL CONTRACTS
General Motors
Harbour Litigation Funding Ltd.
Mercedes-Benz Tells Texas Justices To Ax $115M Fraud Award
Hilton Worldwide Inc.
Mercedes-Benz told the Texas Supreme Court in oral arguments Tuesday
IMF Bentham Ltd.
that a $115 million punitive damages award against it must be tossed
because it's based not on the contract between it and a former business
Johnson & Johnson
partner, but on alleged oral agreements. Read full article
Lehman Brothers Holdings Inc.
LexisNexis Group
Body Glove's Tactics Didn't Hurt Asia Licensee, Jury Says
Linkedln Corp.
Body Glove and its private equity owner, Marquee Brands LLC, didn't harm
Manchester United
the Asia licensee of the watersports company despite engaging in hardball
business tactics during a dispute over licensing rights in the world's most
Mercedes-Benz
populous region, a California federal jury has determined. Read full article
Monsanto Co.
Mylan NV
EFTA00026452

=== Page 3 ===
TAX
National Basketball Association
National Collegiate Athletic
Tax Court Judge Presses IRS On Mylan Legal Fee Deduction
Association
A U.S. Tax Court judge on Tuesday questioned the Internal Revenue
New England Compounding
Service's reasoning for denying Mylan Inc. a $50 million legal fee deduction,
Pharmacy Inc.
challenging the agency's argument that the deduction could not be taken for
Planned Parenthood Federation
litigation related to the generic drug approval process. Read full article
Quill Corp.
PEOPLE
Reed Elsevier
Tampa Bay Buccaneers
Carlton Fields Picks Up K&L Gates Litigator In Miami
The American Law Institute
Carlton Fields said Monday it has added a K&L Gates LLP trial lawyer as a
The American Legion
shareholder in its business litigation and white collar crime practice groups in
The Florida Bar
Miami. Read full article
Twitter Inc.
EXPERT ANALYSIS
UnitedLex Corp.
Wal-Mart Stores Inc.
Property And Casualty Insurers Face A Genomics Revolution
Wayfair LLC
Plaintiffs attorneys are winning big in civil litigation by invoking genomic
Zillow Inc.
susceptibility arguments, and trends suggest that property and casualty
insurers will face more and larger claims as a result. But genomic data can
GOVERNMENT AGENCIES
assist both plaintiffs and defendants, say David Schwartz of Innovative
Science Solutions and William Wilt of Assured Research. Read full article
Federal Bureau of Investigation
Federal Deposit Insurance Corp.
LEGAL INDUSTRY
Federal Reserve System
Food and Drug Administration
Feature
Internal Revenue Service
NewLaw Is Wooing BigLaw's Young Talent
In search of new experiences and more flexibility, some young lawyers are
Pennsylvania Supreme Court
pointing their career paths toward alternative legal service providers. Read
Social Security Administration
full article
Texas Supreme Court
U.S. Attorney's Office
DC Circ. Asks Why Gov't Legal Opinions Are FOIA-Exempt
U.S. Department of Justice
The U.S. Justice Department faced pointed questions from D.C. Circuit
judges Tuesday about its rationale for keeping legal advice to federal
U.S. Supreme Court
agencies from public view. Read full article
U.S. Tax Court
Hilton Sued Over Secret Filming Of NY Bar Exam Taker
A law school graduate who stayed at a New York hotel before taking the bar
exam has sued Hilton and its affiliates for $100 million in Virginia state court,
claiming that secretly filmed footage of her showering in her room was posted
on pornographic websites and emailed to her friends and colleagues. Read
full article
Scottie Pippen Claims Atty-Comedian Trashed Fla. Mansion
NBA Hall of Famer and former Chicago Bulls star Scottie Pippen hit a South
Florida attorney-comedian and her husband with a lawsuit in state court
Monday, accusing them of trashing his $10 million mansion, stealing cutlery
and allowing their pets to urinate all over the property. Read full article
Litigation Funder Validity Poaches Pair From Bentham IMF
Litigation funder upstart Validity Finance LLC said Tuesday it has poached
two ex-litigators from rival Bentham IMF to oversee risk management and
underwriting. Read full article
Insights From 2017-2018 High Court Term And What's Ahead
Many expect the U.S. Supreme Court's new conservative majority to track
rightward, while others wonder if any justices might assert a moderating
influence as the new "swing vote." The court's recent decisions and
upcoming docket provide the best clues about its trajectory, says Chad
Eggspuehler of Tucker Ellis LLP. Read full article
EFTA00026453

=== Page 4 ===
JOBS
Search full listings or advertise your job opening
Employment Associate / NY mid-size law
IP or Patent Partner tired of commuting to
firm
NYC
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New York, New York
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Regional NYS law firm seeks additional
L&E Partner -Mid-sized NYC law firm
partner for White Plains office
Schoen Legal Search
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New York City, New York
White Plains, New York
Labor & Employment Associate
Litigation Associate
Nixon Peabody LLP
Stoel Rives LLP
Jericho, New York
Minneapolis, Minnesota
Matrimonial Litigation Director
Corporate Associate (East Brunswick
Law Offices of Jeffery M. Leving, Ltd.
Office)
Chicago, Illinois
McCarter & English, LLP
East Brunswick, New Jersey
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EFTA00026454


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS) [Contractor]"
Cc:
(USANYS)"
)"
)"
Subject: RE: [EXTERNAL] Fwd: Request for Comment
Date: Thu, 21 Oct 2021 15:45:21 +0000
Agreed. Will handle now.
From:
Sent: Thursday, October 21, 2021 11:42 AM
To:
(USANYS)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
Subject: FW: [EXTERNAL] Fwd: Request for Comment
Hi
Passing this on. It's pretty aggressive to try to contact me through the school where I teach, but defer to you on how to
respond, if at all.
Thanks,
Begin forwarded message:
From: Monique Beals
Date: October 21, 2021 at 11:36:34 AM EDT
To:
Subject: Request for Comment
Hello,
I am a reporter from The Hill, and I wanted to seek any comment you may have on Ghislaine Maxwell seeking private
screenings of potential jurors.
If you have any statement on this, please feel free to reach out.
I apologize for reaching out to you via your Columbia University email address, but wanted to be sure to reach you in the
event you would like to provide a statement.
Best,
Monique Beals
EFTA00026480


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=== Page 1 ===
From:
"
)"
To:
(USAFLS)"
Cc:
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Question re SDFL Epstein file
Date: Thu, 17 Dec 2020 20:14:18 +0000
Embedded: RE:_Question_re_SDFL_Epstein_file.msg
Sender:
Subject: RE: Question re SDFL Epstein file
Message-Id:
<SN5P110MB05427492B09BD2CEFCD6EB4A92C40@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
EFTA00024472


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=== Page 1 ===
From:
To:
Subject: Epstein FOIA Moot
Date: Fri, 26 Mar 2021 19:15:20 +0000
Importance: Normal
Attachments: unnamed
EFTA00024013


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
>, "Berman, Geoffrey (USANYS)"
N
Craig (USANYS)"
i
(USANYS)"
(USANYS)"
i
(USANYS)"
Subject: Re: Epstein Autopsy
Date: Sun, 11 Aug 2019 20:42:51 +0000
Thanks for the update
Sent from my iPhone
On Aug 11, 2019, at 3:38 PM,
(USANYS)
wrote:
Thanks,
Sent from my iPad
On Aug 11, 2019, at 3:30 PM,
(USANYS)
wrote:
,
All,
OCME just completed the autopsy and the findings are consistent with strangulation/hanging. Epstein had a broken
hiatal bone and injuries to the left shoulder that are consistent with hanging. Per OCME, there is no reason to suspect
that Epstein did not hang himself. OCME will wait to finalize the report until after the toxicology reports come back,
and OCME has had an opportunity to review any reports of interviews of the first guards on the scene who discovered
Epstein.
We will continue to keep you posted. Please let us know if you have any questions. Thanks.
EFTA00023982


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Wed, 13 Jan 2021 23:45:32 +0000
The Thursday and Friday times work for me.
From:
Sent: Wednesday, January 13, 2021 6:21 PM
To:
Cc:
Subject: RE:
Sure! They are available tomorrow at 1 and Friday at 3. Monday is MLK Day and I am not sure how that will affect their
schedules right now. They could definitely do next Tuesday at 3:30 also.
From:
Sent: Wednesday, January 13, 2021 5:54 PM
To:
Cc:
Subject:
Hey
- Would you be able to help us find a time to chat with
and the Brass about
?
Just chiefs
and Brass, no team. I think we have pretty decent availability tomorrow and Friday if either works for
But not
urgent, so next week is fine, too, if that's better.
Thanks,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00024989


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
)"
Subject: RE: US V. Epstein
Date: Sun, 19 Jul 2020 23:13:30 +0000
Embedded: spreadsheet.msg
A couple questions on this list. First, are you sure that NYC024392 was provided to us? I ask because as of 7/14 (last
Tuesday), in an email
said we didn't have that drive yet - see the spreadsheet in the attached email - and I also
referred to that number on Wednesday in our call as one we didn't have and CART didn't say anything different.
The other question is, do you have any info on NYC024328 in terms of device, serial number, etc? I ask because looking at
the same chart that
sent in the attached email last Tuesday, there doesn't appear to be *any* device with that
identifier. The list goes 326, 327, 329.
thanks,
From:
(USANYS) [Contractor]
Sent: Thursday, July 16, 2020 15:56
To:
)
Subject: RE: US V. Epstein
The following folders are being sent out for upload to Relativity:
NYC024363
NYC024392
NYC024328
NYC024365
NYC024366
NYC024371
NYC024383
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, July 16, 2020 3:00 PM
To:
)
Subject: US V. Epstein
Hello
I wanted to know if you have a minute to talk.
EFTA00024717

=== Page 2 ===
Thank you.
EFTA00024718


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=== Page 1 ===
RELITED one FEDERAL ino PRISONS SEQUITUR DISTRICT OF
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024376

=== Page 2 ===
COPY
8/10/19
EFTA00024377

=== Page 3 ===
OF OZA ano PRISONS SEQUITUR OF DEPARTMENT
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
EFTA00024378

=== Page 4 ===
FEDERAL BAL our TRO DOMINA JUSTITIA OF F JUSTICE OF SECTIONS
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
$10/19
EFTA00024379

=== Page 5 ===
OF JUSTICE
VEGENAL our ORA DOMINA BUREAU JUSTITIA OF NOTIONAL
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
EFTA00024380

=== Page 6 ===
COPY
8/10/19
EFTA00024381

=== Page 7 ===
VEDERAL OUR PRO DOMINA JUSTITIA OF P JUSTICE DEPARTMENT OF NOTIONAL INSURE
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024382

=== Page 8 ===
FIDER our OF DOMINA BUREAU JUSTITIA OF F JUSTICE OF ISNOSINA
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024383

=== Page 9 ===
EFTA00024384

=== Page 10 ===
OF SEAL MALISTRY ONE 83034 ino SEQUITOR PRISONS* OF
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
61/01/8
EFTA00024385

=== Page 11 ===
ADDRESS and FEDERAL ano SEQUITUR PRISONS* STATE OF
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19C
EFTA00024386

=== Page 12 ===
OF IN AUTHOR ORd FEDERAL ano PRISONS* SEOUITUR OF DEPARTMENT
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024387

=== Page 13 ===
FEDERAL RAL BUREAU OF OUR OF DOMINA OF JUSTICE
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024388

=== Page 14 ===
OF IF VETITLE AMOUNT OFF ino PRISONS* SEQUITUR DISTRIBE OF DEPERTMENT
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024389

=== Page 15 ===
FEDERAL E THE DOMINA BUREAU JUSTITIA OF JUSTICE OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
EFTA00024390

=== Page 16 ===
IF MALISTRY AUTHOR OFF ino SEQUITUR PRISONS * OF DEPERTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19@
EFTA00024391

=== Page 17 ===
ILLINOIS WALLSTA PRO no SEQUITUR PRISONS* OF
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
EFTA00024392

=== Page 18 ===
OF F JUSTICE
BUREAU OF ORd FEDERAL ino PRISONS SEQUITUR
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
61/01/8
EFTA00024393

=== Page 19 ===
STATEMENT FEDERAL our OF DOMINA JUSTITIA OF F JUSTICE OF INNOSTRY
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/19
EFTA00024394

=== Page 20 ===
OF JUSTICE
FEDERAL AL our **O DOMINA BUREAU JUSTITIA DEPARTMENT OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Lieutenant's Office
Type of Incident
INMATE SUICIDE
Date and Time of Incident
08/10/2019 6:33 AM
Inmate Name / Reg. No.
EPSTEIN, JEFFERY REG#76318-054
Location of Incident
ZA
Photograph(s) by
Lt.
Date and Time of Photo
08/10/2019 6:49 AM
COPY
8/10/190
EFTA00024395


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: Request for Jeffrey Epstein Suicide Reconstruction Report
Date: Wed, 16 Sep 2020 13:16:54 +0000
Great. Makes sense.
From:
(USANYS) [Contractor]
Sent: Tuesday, September 15, 2020 4:18 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Request for Jeffrey Epstein Suicide Reconstruction Report
do. And yes, I've asked Annie to help out on this case.
From:
(USANYS)
Sent: Tuesday, September 15, 2020 4:14 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: FW: Request for Jeffrey Epstein Suicide Reconstruction Report
Hi
- can you add this to the next MCC discovery production? Also, is there another paralegal that'll be working on this
case with you?
From:
Sent: Tuesday, September 15, 2020 4:10 PM
To:
(USANYS)
Cc:
Subject: Re: Request for Jeffrey Epstein Suicide Reconstruction Report
- thank you for touching base on this request. Please see the attached, to be produced under the protective order. If it
is to be used publicly, please keep us apprised so we can let our media and leg affairs staff know.
cc'd here,
and his staff can also assist in anything further you need for this case. Thank you for your assistance, and again, apologies
for the delay.
>>>
9/11/2020 12:02 PM>>>
Hello
Please give me a call on this request. My number is 202-598-5491. Thank you-
Assistant Director/General Counsel
Federal Bureau of Prisons
Office of General Counsel
320 First Street, NW
Washington, DC 20534
EFTA00025536

=== Page 2 ===
E-Mail: khyle@bop.gov
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all accompanying documents constitutes sensitive
information. This information is the property of the U.S. Department of Justice.
If you are not the intended recipient of this information, any disclosure, copying, distribution, or the taking of any action in
reliance on this information is strictly prohibited. If you received this message in error, please notify us immediately at the
above number to make arrangements for its return to us.
>>>
(USANYS)" <
> 9/10/2020 5:17 PM >>>
Hi
Omar Daza gave us your contact information. We're looking for a copy of the final suicide reconstruction report relating to
Jeffrey Epstein. We've seen some drafts in documents sent by the BOP to our office, but we'd appreciate having the final.
Can you send it? If you have any questions, we'd be happy to discuss.
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
EFTA00025537


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=== Page 1 ===
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
)
IN RE APPLICATION OF THE
)
UNITED STATES OF AMERICA FOR
)
20 Mag
2.0MAGO1560
AN ORDER PURSUANT TO
)
20 U.S.C. § 1232g(b)(1)(J)(i) and
)
28 U.S.C. § 1651
)
Filed Under Seal
ORDER
This matter having come before the Court pursuant to an application under Title 20,
United States Code, Section 1232g(b)(1)(J)(i), and Title 28, United States Code, Section 1651
which application requests the issuance of an order directing Interlochen Center for the Arts
("Interlochen") and its employees, located at 4000 Highway M-137 Interlochen, MI 49643, and
Interlochen employees, not to notify any other person of the existence of the attached subpoena
seeking records, the Court finds that the applicant has offered reasonable grounds to believe that
such disclosure will result in the intimidation of potential witnesses, or the destruction of or
tampering with evidence, and will seriously jeopardize the investigation.
IT APPEARING that the information sought in the attached subpoena is directed at
establishing the illegal activity under investigation and identifying the individuals responsible for
such activity, there is reason to believe that disclosure of the scope and direction of the inquiry
will result in the intimidation of potential witnesses, destruction of or tampering with evidence,
and will seriously jeopardize the investigation.
IT IS ORDERED that pursuant to Title 20, United States Code, Section 1232g(b)(1)(J)(i),
and Title 28, United States Code, Section 1651, Interlochen and its employees shall not disclose
the existence of the attached subpoena to any other person (except as necessary to carry out the
subpoena) for a period of 180 days from the date of this Order.
EFTA00026851

=== Page 2 ===
IT IS FURTHER ORDERED that this Order and the Application upon which it was
granted are to be filed under seal until otherwise ordered by the Court, except that the
Government may without further order provide copies of the Application and Order as need be to
personnel assisting the Government in the investigation and prosecution of this matter, and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
FEB 1 1 2020
So Ordered, this
day of February 2020
S/Robert W. Lehrburger
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK
UNITED SOUTHERN STATES MAGISTRATE
ROBERT W. LEHRBURGER
DISTRICT OF NEW JUDGE YORK
2
EFTA00026852

=== Page 3 ===
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
February 10, 2020
Interlochen Center for the Arts
4000 Highway M-137
Interlochen, MI 49643
Attn: Jeffrey Jocks, Esq.
jjocks@sondeeracine.com
Re: Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. Pursuant to the accompanying non-disclosure order issued under 20
U.S.C. § 1232g(b)(1)(J)(i) and 28 U.S.C. § 1651, you are prohibited from notifying any person
(except as necessary to carry out the subpoena) of the existence of this subpoena for a period
of 180 days from the date of the order. If you ever plan to notify any person of the existence
of this subpoena, even after the 180-day period, please advise me before you do so, in case
the investigation remains ongoing and the order needs to be renewed.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
Maurene Comey
Assistant United States Attorney
Southern District of New York
(212) 637-2324
EFTA00026853

=== Page 4 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Interlochen Center for the Arts
4000 Highway M-137
Interlochen, MI 49643
Attn: Jeffrey Jocks, Esq.
jjocks@sondeeracine.com
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
February 24, 2020
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. § 2423(a)
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone (212) 384-1000,
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
February 10, 2020
Julby
GEOFFREY S. BERMAN
STATES
United States Attorney for the
Southern District of New York
STATE
COURT
Hanlme Maurene Comey
THE
Assistant United States Attorney
RICT
ICE
One St. Andrew's Plaza
OF
New York, New York 10007
Telephone: 212-637-2324
.gov
EFTA00026854

=== Page 5 ===
RIDER
(Grand Jury Subpoena to Interlochen Center for the Arts
dated February 10, 2020)
Please provide any and all records reflecting the names of all students who attended Interlochen
Arts Camp and/or Interlochen Arts Academy, and each student's period of enrollment, for the
period January 1, 1994 through December 31, 1998.
N.B.: Personal appearance is not required if the requested records are (1) produced by on or before
the return date to Special Agent
Federal Bureau of Investigation, 26 Federal
Plaza, New York, NY 10278, telephone (212) 384-1000,
; and (2) accompanied
by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE
IN ELECTRONIC FORMAT IF POSSIBLE.
IMPORTANT: NON-DISCLOSURE ORDER
Pursuant to the attached order, you are not to disclose any information relating to this grand jury
subpoena to any person (except as necessary to carry out the subpoena). Disclosure could impede
or obstruct an investigation.
3
EFTA00026855

=== Page 6 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated February 10, 2020, and signed by Assistant
United States Attorney
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00026856


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=== Page 1 ===
From:
To:
Subject: Re: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 02:40:34 +0000
Good luck!!
Sent from my iPhone
On Nov 28, 2021, at 9:59 AM
wrote:
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:
@bop.gov>
>
Subject: Re: FW: MCC Visit Thursday
Date: Wed, 14 Aug 2019 19:47:18 +0000
Thank you. Everything is set. See you in the morning.
>>>
(USANYS)"
> 8/14/2019 12:49 PM>>>
Resending, I got an error last time.
From:
USANYS)
Sent: Wednesday, August 14, 2019 12:41 PM
To:
n
is
@bop.gov>
Cc:
(USANYS)
Subject: RE: MCC Visit Thursday
Ed O'Callahan - Principal Deputy Attorney General
Geoffrey Berman - US Attorney
From:
Sent: Wednesday, August 14, 2019 12:26 PM
To:
@bop.gov>;
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
EFTA00024400

=== Page 2 ===
New York, New York 10007
p:
f:
>>>
>
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:
@bop.gov>
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:
@bop.gov>
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
p
f:
>>>
> 8/13/2019 2:05 PM>>>
Adam,
The list of visitors from our office is below:
Geoffrey Berman
EFTA00024401

=== Page 3 ===
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,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00024402


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=== Page 1 ===
From:
To:
Subject:
(
wife),
and Epstein's foundation 1 of 2
Date: Sun, 14 Jul 2019 15:52:57 +0000
1) Look at last page 17 of one of Epstein's Form 990 reports--see the concentration purchase and flip in TenCent
and Western Digital?--More than half the proceeds are bet on these two companies:
http://90s.foundationcenter.org/99opf_pdf_archive/660/660789697/660789697_201712_990PFpd1
2) On the AUDIT COMMITTEE of TenCent is accountant
:
https://www.tencent.com/en-us/articles/13006381526480930.pdf
ard committees:- Audit Committee Corporate Governance Committee Investment Committee Nomination
Committee Remuneration Committee
3) Now, let's see who else
knows? My, my! None other than
wife!!!!
My, my, he's on the board of Blue Chip Fund with
Blue Chip Growth Fund - SEC.gov
https://www.sec.gov/Archives/edgar/data/902259/..bcg_811-07059.htm
1.2, Elect Director
,
Management, For, For. 1.3, Elect
3, Elect Director
Management, For, For. 4, Ratify Auditors
3a2, Reelect
as
Director, Management, For, For. 3b, Authorize Board
<SEC-DOCUMENT>0001193125-15-308249.txt: 20150831 <SEC
https://www.sec.gov/Archives/edgar/data/8229777./0001193125-15-308249.xt
94 as Non-independent Director 6.3 Elect
with Shareholder No.
Director For Against
Management 3.1b Elect
as Director
For Management 1.4 Elect Director
For For Management 2
I do not have time to run Western Digital's traps, but this is more than enough for you to take a look.
EFTA00026734


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: Call this week
Date: Thu, 26 Mar 2020 00:45:59 +0000
Same here, thanks.
Sent from my iPhone
On Mar 25, 2020, at 8:23 PM,
)
wrote:
Either totally fine for me
Sent from my iPhone
Begin forwarded message:
From: Gloria Allred
Date: March 25, 2020 at 20:21:45 EDT
To:
)"
Cc:
)"
)"
Subject: RE: Call this week
Yes. What time tomorrow is better for you, 3 P.M. e.s.t. or 4P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 1:55 PM
To: Gloria Allred
Cc:
is
Subject: Call this week
Gloria,
EFTA00025186

=== Page 2 ===
Would you have time for a call with the SDNY Epstein team tomorrow or Friday? We would like to provide you with a
bit of an update and discuss some of your clients in particular.
Hope you are staying safe and healthy.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
EFTA00025187


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
October 2, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Hand me
Assistant United States Attorneys
Enclosure
EFTA00023695


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE: Epstein Documents from BOP without Green Watermark
Date: Mon, 12 Apr 2021 16:07:52 +0000
Hi
Thank you. Let me circle up with a few folks, including BOP, about how best to proceed here, and I will get back to you.
Thanks,
From:
(USANYS)
Sent: Monday, April 12, 2021 11:36 AM
To:
(USANYS)
is
(USANYS)
Subject: RE: Epstein Documents from BOP without Green Watermark
Hi
We requested these from the BOP, and they provided a set of documents, which we then produced to defense counsel.
We did not do a page by page comparison between the redacted set and the unredacted set, so we can't guarantee that
they are "comprehensive." But we can provide you with what we have, assuming that there aren't any issues with us
sharing in that way.
Best,
From:
(USANYS)
Sent: Sunday, April 11, 2021 12:27 PM
To:
(USANYS)
is
(USANYS)
Subject: Epstein Documents from BOP without Green Watermark
and
I recall that at some point you requested a version of the Epstein FOIA documents from BOP without the translucent
green watermark they put on the withheld documents. Do you have those saved down somewhere? Although the Court
has not put in a specific order yet, I think it's likely that we'll need to produce documents without the translucent green
marking to the Court. I have versions without the watermark for some of the docs, but it looks like not all. Do you have a
comprehensive set somewhere?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
EFTA00026909


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Letter regarding jail conditions and court appearance
Date: Fri, 21 Aug 2020 18:14:18 +0000
I think that decision lies on the other side of the wall. Thanks
From:
(USANYS)
Sent: Friday, August 21, 2020 2:10 PM
To:
)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Letter regarding jail conditions and court appearance
Thanks
What's our position on his request to appear telephonically week? Or should I check with the other side
of the wall?
From:
Sent: Thursday, August 20, 2020 2:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: FW: Letter regarding jail conditions and court appearance
FYI
From: Bruce Barket
Sent: Thursday, August 20, 2020 12:50 PM
To:
Cc: Aida Leisenring
>; tonyricco
>; Michael Bachrach
>; Kenneth J. Montgomery Esq
>; 'john diaz
(
)'
is
i
is
(USANYS)
is
(USANYS)
is
is
(USANYS)
>
Subject: Letter regarding jail conditions and court appearance
I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the MCC
and the prosecution team as well as firewall counsel. Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
EFTA00026748

=== Page 2 ===
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
EFTA00026749


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
)"
(USANYS)"
Cc:
"
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Bec:
"
Subject: US V. Epstein
Date: Thu, 15 Oct 2020 16:19:08 +0000
Embedded: US_v._Epstein.msg
Sender:
Subject: US V. Epstein
Message-Id:
<SN5P110MB0559894FE5BAC7536267B27DF8020@SN5P110MB0559.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
Cc:
Cc:
EFTA00027050


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
Cc:
(USANYS)"
)"
)"
Subject: RE: Declaration
Date: Mon, 02 Aug 2021 13:28:34 +0000
Inline-Images: image003.jpg; image004.jpg
Thanks!
From:
(USANYS) [Contractor]
Sent: Monday, August 2, 2021 9:26 AM
To:
is
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Cc:
(USANYS)
i
is
Subject: RE: Declaration
Hi
I hope you had a great weekend! They've been saved in the
testifying witness 3500 and witness folder.
Thanks,
From:
Sent: Saturday, July 31, 2021 8:54 PM
To:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Cc:
(USANYS)
i
>;
Subject: FW: Declaration
Hi,
Would one of you please save the attached 2 pdfs in the testifying witness 3500 and witness folders for
on
the Epstein share?
Thanks,
From: Quigley, Brendan
Sent: Friday, July 30, 2021 12:22 PM
To:
)
Subject: Declaration
EFTA00025073

=== Page 2 ===
Brendan F. Quigley [bio]
Partner
Baker Botts L.L.P.
Confidentiality Notice:
The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address above
and destroy any and all copies of this message.
EFTA00025074


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=== Page 1 ===
From:
To:
Subject: Suppression Opp
Date: Sun, 21 Feb 2021 22:57:33 +0000
Attachments: Motion_to_Suppress_Opp_v5.docx.
Hi team,
I turned the edits suggested by the chiefs.
asked that I get this back to them tomorrow. I am hoping to get it back to
them by tomorrow early afternoon so I can turn their next round of edits and send to
to review as soon as possible.
already reviewed the initial draft I sent to the chiefs, but I wanted to make sure you all had an opportunity to
review and comment on this before I send this back to the chiefs. I know it is quite lengthy, so apologies in advance.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00027081


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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 24, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02775073 through SDNY_GM_02775777.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. 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.
An index of the materials contained in this production is below:
EFTA00024987

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02775073
SDNY GM 02775087
JPMC records
Confidential
SDNY GM 02775088
SDNY GM 02775777
Lockheed Martin records
Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00024988


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=== Page 1 ===
Event: Epstein Meeting (Please hold the time)
Start Date: 2020-01-16 19:00:00 +0000
End Date: 2020-01-16 20:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2020-01-10 20:22:40 +0000
Date Modified: 2020-01-10 20:22:40 +0000
Priority: 5
DTSTAMP: 2020-01-10 18:54:32 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00024252


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=== Page 1 ===
From:
"
To:
Bcc:
Subject: Potential Request for Material Relating to Jeffrey Epstein
Date: Wed, 17 Feb 2021 22:39:00 +0000
Attachments: Scarola_Touhy_Ltr.pdf
Mr. Scarola,
I understand that you may wish to submit a request to the Department of Justice for material relating to Jeffrey
Epstein. I am attaching a letter to assist you with that process. Please feel free to give me a call if you have any
questions.
Take good care.
Chief, Civil Division
U.S. Attorney's Office, SDNY
EFTA00023767


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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell 02879-509
Date: Thu, 19 Nov 2020 00:12:50 +0000
Sorry
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
Date: 11/18/20 6:29 PM (GMT-05:00)
To:
Subject: Re: Ghislaine Maxwell 02879-509
)" 11/18/2020 18:29
What number should I call?
On Nov 18, 2020, at 5:59 PM,
wrote:
Please call me at your earliest convenience.
BOBBI C STERNHEIM 11/18/2020 5:51 PM
Hi
I have a confirmed legal call scheduled for tomorrow (Thursday)
and a confirmed in-person visit scheduled for Saturday
with my client, Ghislaine Maxwell 02879-509.
I am informed that Ms. Maxwell received a nasal swab test today
and is being placed in the SHU for 14 days.
Please confirm:
-whether she I being quarantined.
If so, please explain:
- the reason for the quarantine
- the duration of the quarantine
- whether she will be given legal calls
- whether her legal visits are canceled.
Your prompt response is requested and appreciated.
Thank you-
Bobbi
EFTA00026458

=== Page 2 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
EFTA00026459


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=== Page 1 ===
From: Gary Bloxsome
To:
)"
)"
>, Daniel Cundy
Jennifer Richardson
)"
Subject: DOJ ongoing Investigation.
Date: Fri, 14 Feb 2020 17:00:13 +0000
Inline-Images: image543915.jpg; image517195.jpg
Dear
We and the Duke of York set out to assist your investigation when the DOJ asked for his help in January 2020.
However, we regret to say that we have reached the conclusion that the DOJ's dealings with the Duke of York
have not been designed to seek his assistance in investigating and prosecuting the targets of the investigation but
instead have been used only to gather publicity for Mr Geoffrey S. Berman, the United States Attorney for the
Southern District of New York.
It is essential, if justice is to be done for Epstein's victims, that a proper and thorough criminal investigation is
carried out. Although the public record indicates your office (SDNY) has been actively investigating Mr. Epstein
and other targets for more than 2 years, the first time you ever attempted to make contact and request The Duke
of York's help was on 2 January 2020.
The Duke instructed my firm to make contact with you pertaining to this request. When we made contact, you
confirmed that the Duke of York was not and is not a target of the US criminal investigation.
Due to the publicity surrounding the investigation, we asked you to confirm that our discussions and any
interview arrangements would remain confidential, in accordance with your rules. The Duke did not want to add
to the media circus that has now surrounded the investigation. On 10 January 2020 you confirmed that any
arrangements would indeed be kept confidential.
We indicated that we would refer back to you once we had dealt with the various issues and procedures, which
would need to be addressed to enable the Duke to cooperate to the fullest extent possible, including the need to
obtain all the information that you might need to consider. It was at that time that we informed you, by email
dated 20 January, that such preliminary issues would be dealt with within 14 days. It was also in that email that
we confirmed that The Duke has a strong desire to cooperate with the ongoing investigation by the DOJ.
Instead of waiting to hear from us (as you indicated on 22 January 2020), Mr Geoffrey S. Berman, the United
States Attorney for the Southern District of New York, chose to make a public statement about the Duke on 27
January 2020. This led to press reports that there had been "a wall of silence" and that there had been "zero co-
operation" by the Duke. These statements were not true. They should not have been made.
Quite apart from your promise of confidentiality, in England it would not be thought to be in the interests of
justice for any prosecutor or investigator to make public statements about witnesses who may be willing, in
confidence, to assist their investigation.
In England, prosecutors and investigators try to make sure that the investigation and trial of serious criminal
cases take place in court and not in press conferences or publicity battles.
When we complained about the way the Duke (and we) had been treated by the DOJ, you refused to apologise
and you have now also gone back on your promise that any arrangements for the interview will be confidential.
EFTA00023802

=== Page 2 ===
We cannot advise the Duke to speak to prosecutors who cannot be trusted to deal with him fairly nor to treat
what he says or does confidentially. He has reluctantly accepted our advice that, in those circumstances, there is
no purpose to be served in continuing to try to assist further.
Finally we have no wish to engage in any further publicity battle about the DOJ's conduct and for that reason we
ask that you treat this email as private and confidential.
Regards
Gary
Gary Bloxsome I Partner
RANKED IN
Chambers
LEGAL
UK
500
2020
TOP TIER
Blackfords
Leading Firm
2020
LLP
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00023803


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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:41:55 +0000
Inline-Images: image001.png
Thanks!
From:
Sent: Thursday, July 2, 2020 1:38 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Great work team!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF 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,
EFTA00024523

=== 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.
EFTA00024524

=== 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.
EFTA00024525


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=== Page 1 ===
*jeevacation*
*jeeitunes*
*jeevacation*
*littlestjeff*
*jeffreyepsteinorg*
*jeeproject*
*jeffreyepstein*
*gmax*
*pipex*
*aace*
*abx17*
*passenger*
*manifest*
*flight*
*massage*
*masseuse*
*vibrator*
Maxwell
Ghislaine
Invisible
Andrew
Prince
Expedia
EFTA00027057

=== Page 2 ===
Jet
Gulfstream
Boeing
Hyperion
Log
EFTA00027

=== Page 3 ===
EFTA00027059

=== Page 4 ===
EFTA00027060

=== Page 5 ===
EFTA00027061

=== Page 6 ===
EFTA00027062


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE:
Date: Wed, 09 Sep 2020 13:49:48 +0000
Attachments: PC_Unit__Short_Form_Update.9.4.20.docx
Sure, attached.
From:
(USANYS)
Sent: Wednesday, September 9, 2020 9:16 AM
To:
(USANYS)
Subject
Because I look at all the unit updates to clear others' conflicts, could you make sure that
is not included
in the regular update? If it is included in the one that you just sent me, kindly send me another one without it.
Thanks, sorry for the bother.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00026617


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=== Page 1 ===
From:
)"
To:
(NY)
(FBI)"
Cc:
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Date: Wed, 07 Apr 2021 15:28:43 +0000
Thanks
!
The files
is bringing over can all be saved in the same folder I sent at the bottom of this email
chain.
From:
(USANYS) [Contractor]
Sent: Wednesday, April 7, 2021 11:26 AM
To:
(NY) (FBI)
>;
Cc:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Sounds good, thank you!
From:
(NY) (FBI)
Sent: Wednesday, April 7, 2021 11:09 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Hey
I'm having some issues with my usa fx account. I have to drop some other media off, so I'll put this on another disc and
drop it off. I can drop it all off early afternoon if that's alright.
Special Agent
FBI New York Field Office
On Apr 7, 2021 9:48 AM,
(USANYS) [Contractor]"
wrote:
Hey
Just wanted to follow up on getting the folder "1B 1-14" on USAfx. Please let us know when you've been able to upload it,
thanks!
From:
Sent: Tuesday, April 6, 2021 1:14 PM
To:
(NY) (FBI)
i
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
EFTA00027086

=== Page 2 ===
Subject: FW: CD with Maxwell files
Thanks so much,
(cc'd) will make another copy this afternoon and will send it to you via USAfx.
From:
(USANYS) [Contractor]
Sent: Tuesday, April 6, 2021 1:12 PM
To:
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Just confirmed with
that we'll need a replacement of the folder called "1B 1-14" since it won't copy for him either,
probably due to the files getting corrupted somehow when the disc was burned. The folder/its contents may be small
enough that the FBI could send it via USAfx rather than having to burn a new disc, but we'll need a replacement of this
folder either way.
From:
Sent: Monday, April 5, 2021 4:27 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
y
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Great, thank you!
From:
(USANYS) [Contractor]
Sent: Monday, April 5, 2021 4:20 PM
To:
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Hi
Four of the five folders from the disc have successfully uploaded to the folder path linked below, but the fifth folder (1B 1-
14) contains at least one file that will not copy off of the disc (not sure if the file is corrupted or what the issue is exactly).
l'll check with the IT folks and
to see if they're able to copy the remaining folder off the disc or if we'll need the FBI
to recopy and resend it. I will keep you posted on the status of this last folder.
Thanks,
From:
(USANYS) [Contractor]
Sent: Monday, April 5, 2021 2:04 PM
To:
(USANYS) [Contractor]
Subject: FW: CD with Maxwell files
Thank you so much!
From:
Sent: Monday, April 5, 2021 1:55 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
EFTA00027087

=== Page 3 ===
Subject: CD with Maxwell files
Hi
and
On Friday, the FBI brought me a CD containing additional files that I need to review for Maxwell. It should be sitting in my
office on the 4th floor on my keyboard at my desk. Would one of you (or another paralegal who is in the office) be able to
please grab the CD and load its contents onto the Epstein share? You can save everything from the CD here:
Thanks so much,
EFTA00027088


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=== Page 1 ===
From:
To:
Subject: Declined: Epstein Meeting (Please hold the time)
Date: Fri, 10 Jan 2020 19:06:03 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From: The Bloomberg Open <noreply@mail.bloombergbusiness.com>
To:
Subject: PPP puzzle
Date: Tue, 07 Jul 2020 11:09:20 +0000
Bloomberg
Good morning. Here's what you need to know to start your day.
Venture capital firms deny seeking PPP loans.
The Fed's Bostic warns the recovery is stalling.
Ghislaine Maxwell arrives in New York for hearing.
Five Things You Need to Know
A handful of venture capital firms said they didn't seek bailouts or get
money even though yesterday's list of PPP recipients showed otherwise.
Index Ventures and Foundation Capital, both listed as having been
approved for more than $1 million, are among those saying they never
applied for funding. Andreessen Horowitz's loan in question went to a
portfolio company for which it's the beneficial owner.
The list also included: Companies with ties to President Trump, more
than 88,000 loans for religious organizations, a number of investment firms
and some nonprofit groups that advocate against such massive
government spending. Chinese companies including conglomerate HNA
and affiliates of a state-owned defense giant were among recipients. Jacob
Gottlieb, whose $8 billion hedge fund shut amid an insider trading
scandal also appeared. And agriculture, forestry, fishing and hunting
companies got at least $6.4 billion.
Virus latest: Novavax got a $1.6 billion U.S. award for vaccine
development. Shares jumped 27% premarket. Atlanta Mayor Keisha Lance
Bottoms said she tested positive. Texas cases rose 2.7%, pushing total
infections above 200,000. Brazil's Jair Bolsonaro underwent another test
after showing symptoms. The Australian state of Victoria announced a six-
week lockdown across metropolitan Melbourne. Follow the developments
with our Virus Update.
EFTA00026424

=== Page 2 ===
Europe's economy will be hit more than previously estimated this year
and take longer to recover, the European Commission said. It sees euro-
area GDP slumping 8.7%, a percentage point deeper than it predicted in
May, with risks high and mainly to the downside. Forecasts for France,
Italy and Spain were lowered to contractions of more than 10%, while
Germany was upgraded a tad to -6.3%.
U.S. futures fell with shares in Europe and Asia. Treasuries and the dollar
rose. Oil and gold declined. The Aussie slipped after Melbourne was
locked down. All Stoxx Europe 600 industry groups declined and Bayer
slid after its plan for handling future Roundup cancer claims hit a snag. In
Asia, Chinese stocks powered ahead for a sixth day.
Map of the Day
Keystone XL hit a roadblock. The Supreme Court voted to bar U.S.
construction on the oil-sands pipe, dealing a blow to Trump's bid to
proceed and to Canadian producers wanting to move more oil across the
border. Most work will be delayed to next year, unless Joe Biden wins the
election that is. He's vowed to veto the project.
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join now.
What to Keep an Eye On
The U.S. rebound is at risk of stalling because of the Sun Belt infection
spike, Fed official Raphael Bostic said. High-frequency data showed a
EFTA00026425

=== Page 3 ===
leveling off of business openings and mobility, the Atlanta Fed chief told
the FT. The trajectory will be "a bit bumpier than it might otherwise."
The U.S. may ban TikTok. Michael Pompeo told Fox he's looking at a ban
on Chinese social media apps, specifically TikTok. The company
will remove its app from Hong Kong stores in coming days, the first
internet service to exit the city after China enacted new national security
laws. Its pullout may benefit Beijing by removing a forum pro-democracy
protesters use to post videos.
Tech industry concerns overshadowed Samsung's profit beat. Operating
profit of 8.1 trillion won ($6.8 billion) beat consensus for 6.2 trillion won.
Shares fell as the figures were helped by a one-time gain in the display
business, which some analysts estimated was more than 1 trillion won in
compensation from Apple for fewer-than-promised display orders,
suggesting weakness in the sector.
Jeff Bezos, Mark Zuckerberg, Sundar Pichai and Tim Cook will testify to
Congress on July 27. The appearances before a panel investigating
competition in the tech industry may be virtual. It's Bezos's first time to
testify. Zuckerberg and Sheryl Sandberg are set to meet civil rights leaders
today, after major advertisers boycotted Facebook for not doing enough to
combat racism and voter suppression.
Opinion
China's future credibility will be determined by how it treats Hong Kong,
Bloomberg Opinion's editors write. Beijing may have imposed the national
security law because its believes Western rivals are in disarray, or to
distract from its weakened economy. Nations should oppose
China's attempts to assert territorial claims by force, weaken international
institutions and advance goals through intimidation.
This may be the time for investors who want to save the Brazilian
Amazon, writes Clara Ferreira Marques for Bloomberg Opinion. They can
support green incentives or threaten to divest with the promise to reinvest
if behavior improves. Investors can't dictate government action, but they
can point to portfolio risk and cause plenty of pain. Money talks.
What Everybody's Talking About
EFTA00026426

=== Page 4 ===
The woman who called the police on a Black man watching birds in
Central Park in May was charged with falsely reporting an incident, a
misdemeanor. Amy Cooper, who's White, accused the bird watcher,
Christian Cooper (no relation), of threatening to attack her after he asked
her to keep her dog on a leash. A video of the encounter was posted to
Facebook, where it went viral.
Ghislaine Maxwell, who's being held in a federal jail in New York, is likely
to be formally charged and enter a plea on July 14. District Judge Alison
Nathan proposed the hearing be held by videoconference. The former
Jeffrey Epstein associate agreed to the remote hearing and the date in a
letter to the judge.
By the Way
The Kansas City Chiefs locked in the NFL's most dynamic player for
another decade. Quarterback Patrick Mahomes agreed to a 10-year
extension worth up to $503 million, the AP reported. Mahomes, 24, took
the Chiefs to their first Super Bowl title in 50 years. It's the richest contract
in professional sports history, surpassing Mike Trout's $426.5 million deal
with the Angels.
Photographer: Tom Pennington/Getty
FOLLOW US
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Americas newsletter.
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Bloomberg L.P. 731 Lexington, New York, NY, 10022
EFTA00026427


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=== Page 1 ===
From:
)"
To: "Martin G. Weinberg"
Cc:
)"
)"
>, "Miller, Michael"
>, Reid Weingarten
Subject: Re: US V Epstein
Date: Wed, 14 Aug 2019 20:41:45 +0000
Marty,
That time works for us, thanks. Could you please circulate a dial-in?
Thanks.
Sent from my iPhone
On Aug 14, 2019, at 11:23 AM, Martin G. Weinberg
wrote:
Alex, Mike and I are authorized to continue the discussion of potential civil forfeiture issues with you. Are you available
at 930 tomorrow morning? Thanks
Martin G. Weinberg, Esq.
Boston, MA 02116
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of
the contents of this message is prohibited.
EFTA00024407


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=== Page 1 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
Plaintiff,
No. 15 Civ. 7433 (LAP)
-against-
MEMORANDUM & ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed Defendant Ghislaine Maxwell's letter
requesting reconsideration of the Court's July 23, 2020, decision
to unseal (1) the transcripts of Ms. Maxwell's and Doe l's
depositions, and (2) court submissions excerpting from, quoting
from, or summarizing the contents of the transcripts. (See dkt.
no. 1078.)
Ms. Maxwell's eleventh-hour request for reconsideration is
denied. As Ms. Maxwell acknowledges in her letter, reconsideration
is an "extraordinary remedy." In re Beacon Assocs. Litig., 818 F.
Supp. 2d 697, 701 (S.D.N.Y. 2011) (quoting In re Health Mgmt. Sys.
Inc. Sec. Litig., 113 F. Supp. 2d 613, 614 (S.D.N.Y. 2000)). Such
motions "are properly granted only if there is a showing of: (1)
an intervening change in controlling law; (2) the availability of
new evidence; or (3) a need to correct a clear error or prevent
manifest injustice." Drapkin V. Mafco Consol. Grp., Inc., 818 F.
Supp. 2d 678, 696 (S.D.N.Y. 2011). "A motion for reconsideration
1
EFTA00024875

=== Page 2 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 2 of 4
may not be used to advance new facts, issues or arguments not
previously presented to the Court, nor may it be used as a vehicle
for relitigating issues already decided by the Court." Bennett V.
Watson Wyatt & Co., 156 F. Supp.2d 270, 271 (S.D.N.Y. 2001).
Here, Ms. Maxwell's request for reconsideration hinges on her
assertion that new developments, i.e., her indictment and arrest,
provide compelling reasons for keeping the deposition transcripts
sealed. (See dkt. no. 1078 at 5.) But, despite Ms. Maxwell's
contention that she could not address the effect of those events
in her objections because they occurred after the close of
briefing, (id.), 1 this is plowed ground. Indeed, in her original
objection to unsealing, Ms. Maxwell argued that the specter of
ongoing criminal investigations into unknown individuals
associated with Jeffrey Epstein--a group that, of course, includes
Ms. Maxwell--loomed large over the Court-ordered unsealing
1 The Court notes as a practical matter that Ms. Maxwell was
arrested on July 2, 2020--that is, three weeks prior to the Court's
July 23 decision to unseal the materials at issue. To the extent
that they relate to the to the Court's balancing of interests in
the unsealing process, the issues that Ms. Maxwell raises in her
request were surely plain the day that Ms. Maxwell was apprehended.
Ms. Maxwell, however, did not seek to supplement her objections to
unsealing despite ample time to do SO. In fact, the Court notified
the parties on July 21, 2020, that it would announce the unsealing
decision with respect to Ms. Maxwell's deposition, together with
other documents, on July 23. (See dkt. no. 1076.) Even then, Ms.
Maxwell made no request for delay or to supplement her papers.
Ms. Maxwell did not raise her "vastly different position,"
(Transcript of July 23 Ruling at 16:2-3), until moments after the
Court had made its decision to unseal the relevant documents.
2
EFTA00024876

=== Page 3 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 3 of 4
process. (See dkt. no. 1057 at 5.) This argument, specifically
Ms. Maxwell's concern that unsealing would "inappropriately
influence potential witnesses or alleged victims," (id.), and her
reference to "publicly reported statements by Plaintiff,
Plaintiff's counsel, the United States Attorney for the Southern
District of New York, and the Attorney General for the U.S. Virgin
Islands" about those investigations, (id.), carried with it the
clear implication that Ms. Maxwell could find herself subject to
investigation and, eventually, indictment. The Court understood
that implication as applying to Ms. Maxwell and thus has already
considered any role that criminal charges against Ms. Maxwell might
play in rebutting the presumption of public access to the sealed
materials. Ms. Maxwell's request for reconsideration of the
Court's July 23 ruling is accordingly denied.
Given the Court's denial of Ms. Maxwell's request for
reconsideration, the Court will stay the unsealing of Ms. Maxwell's
and Doe l's deposition transcripts and any sealed or redacted order
or paper that quotes from or discloses information from those
deposition transcripts for two business days, i.e., through
Friday, July 31, 2020, so that Ms. Maxwell may seek relief from
the Court of Appeals. Any sealed materials that do not quote from
or disclose information from those deposition transcripts shall be
unsealed on July 30, 2020, in the manner described by the Court's
Order dated July 28, 2020. (See dkt. no. 1077.) Ms. Maxwell's and
3
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=== Page 4 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 4 of 4
Doe l's deposition transcripts and any sealed materials that quote
or disclose information from them shall be unsealed in the manner
prescribed by the July 28 Order on Monday, August 3, 2020, subject
to any further stay ordered by the Court of Appeals.
so ORDERED.
Dated:
New York, New York
July 29, 2020
Loutta a Preska
LORETTA A. PRESKA
Senior United States District Judge
4
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Submission on behalf o
Date: Tue, 17 Mar 2020 20:16:20 +0000
totally understand, and we appreciate you letting us know. That's not a problem.
thanks,
On Mar 17, 2020, at 15:46,
wrote:
I am working on the new draft of this submission but it is going slower than I expected.
has been in an
emotionally and psychologically fragile state, and because of the Coronavirus, we cannot get
the proper
therapy which
needs. We have suggested
go back to Florida, so at least
can be in
home and not
shut up in a stranger's apartment here in NYC. Additionally, we attorneys have all shut our offices and are
working at home, leading to a great loss in productivity.
So, realistically I am hoping to get you the new draft tomorrow afternoon.
Sent from my iPhone
On Mar 12, 2020, at 8:49 PM,
wrote:
Confirming receipt, thanks.
From:
Sent: Thursday, March 12, 2020 20:40
To:
Cc:
is
Subject: Submission on behalf of
has shared a link to the following document:
Submission on behalf of
Unk
nown
profile
EFTA00025181

=== Page 2 ===
Attached is a draft of the factual statement, just so that you can better understand the facts that we are
presenting.
We feel that given
abuse, and given the fact that we see her basically as a cog in Epstein's wheel,
acting entirely at his direction and doing what she did at a time that she herself was a very vulnerable victim,
a non-pros would be the appropriate disposition. But we want to discuss this with you before we finalize this
and make a submission.
Thanks,
Open in Docs
Logo for
Google Docs: Create and edit documents online.
Google Docs
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
You have received this email because someone shared a document with you from Google Docs.
EFTA00025182


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein-related files
Date: Thu, 03 Sep 2020 14:42:10 +0000
Hi
I hope you are doing well. We spoke about a year ago regarding the Jeffrey Epstein case, and I am reaching back out now
to request assistance in the discovery process for my office's related prosecution of Ghislaine Maxwell. Would your office
be willing to share with us a copy of its files relating to your prior investigation and prosecution of Epstein?
I'm happy to have a call to discuss further, and please let me know if there is someone else in your office I should speak
with regarding this request. I can be reached any time on my cellphone at
Thank you very much for your help.
Best,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Draft letter to Judge Nathan re Maxwell discovery
Date: Mon, 28 Sep 2020 22:10:25 +0000
Embedded: RE:_Draft_letter_to_Judge_Nathan_re_Maxwell_discovery.msg
Sender:
Subject: RE: Draft letter to Judge Nathan re Maxwell discovery
Message-Id:
<DM3P110MB0265CF154759AFC999EE0BBF89350@DM3P110MB0265.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
To:
To:
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=== Page 1 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 1 of 10
FedEx Tax ID: 71-0427007
EPSTEIN & CO INC
Billing Account Shipping Address:
J EPSTEIN & CO INC
MRS SHERMAN
US
Questions?
Phone:
M-F 7-6 (CST)
Fax:
Invoice Summary Dec 25, 2000
Internet:
www.fedex.com
Domestic Services
FedEx News!
Transportation Charges
264.31
FedEx Holiday Operating Schedule
Special Handling Charges
20.57
Monday, Dec. 25 (Christmas)- Closed
Tuesday, Dec. 26- Normal FedEx service and delivery
Total Charges
USD $
284.88
commitments resume.
Sun., Dec. 31 (New Year's Eve) - Closed
Mon., Jan. 1 (New Year's Day) - Closed
Normal FedEx service and delivery commitments resume Tuesday
January 2. For complete details regarding our operating
Schedules and Money-Back Guarantees, please visit fedex.com
Or call us at 1.800.Go.FedEx (800-463-3339)
To ensure proper credit, please return this portion with your payment to FedEx.
Please do not staple or fold.
Invoice
Account
Remittance Advice
Amount Due
Number
Number
Your Payment is due by Jan 09, 2001
5-678-61193
USD $284.88
1144208156786119394002848857
SP 01 000001 97702 A 1 ASNGLP
EPSTEIN & CO INC
FedEx
P.O. Box 1140
Memphis TN 38101-1140
For change of address, check here and complete form on reverse side.
EFTA00024648

=== Page 2 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 2 of 10
FedEx
Federal Express
Please indicate change in address for the account # listed below:
Physical Address
Billing Address
Mailing Address
Account Number: 1144-2081-6
Name:
Address:
Apt./Suite:
City:
State:
Zip:
Phone: ( )
Fax: ( )
Authorizing Signature:
EFTA00024649

=== Page 3 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 3 of 10
Payment Type Summary
Original
Shipper
Number of Airbills
15
Transportation Charges
236.19
Special Handling Charges
9.45
Total
USD $
245.64
Number of Airbills
15
Total Charges
USD $
245.64
Recipient
Number of Airbills
1
Transportation Charges
28.12
Special Handling Charges
11.12
Total
USD $
39.24
Number of Airbills
1
Total Charges
USD $
39.24
TOTAL AIRBILLS
16
TOTAL CHARGES
USD $
284.88
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=== Page 4 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
1144-2081-6
Page 4 of 10
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=== Page 5 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 5 of 10
Payment Type Detail (Original)
Picked up: Dec 14, 2000
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge - FedEx must apply a temporary fuel surcharge to reflect current market conditions as they relate to fuel costs.
Distance Based Pricing, Region 8
Airbill
824463008565
Sender
Recipient
Service Type FedEx 2Day
J EPSTEIN
Package Type Customer Packaging
J EPSTEIN & CO INC
Region
8
Pieces
1
Weight
3.0 lbs. 1.4 kgs
Delivered
Dec 18. 2000 15:21
Transportation Charge
11.02
Service
Fuel Surcharge
0.44
Area Code
2R
Signed By
Total Transportation Charges
USD $
11.46
Bundle ID
000
FedEx Internal Use: 354201380/0012002/
EFTA00024652

=== Page 6 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 6 of 10
Payment Type Detail (Original)
EFTA00024653

=== Page 7 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 7 of 10
Payment Type Detail (Original)
EFTA00024654

=== Page 8 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 8 of 10
Payment Type Detail (Original)
EFTA00024655

=== Page 9 ===
FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 9 of 10
Payment Type Detail (Original)
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FedEx.
Invoice No:
5-678-61193
Invoice Date:
Dec 25, 2000
Account Number:
Page 10 of 10
Payment Type Detail (Original)
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=== Page 1 ===
Victim Services Division Documentation of Services
Download Date: 04-SEP-20
From: 01-APR-20
To: 30-JUN-20
Victim Name:
FBI Case Number: 31E-NY-3027571
Downloaded By:
Service Type
Number of Services
Follow Up Contact Phone Call
1
Follow Up Contact Text
1
Resource / Referral Provided Federal Agency
1
Resource / Referral Provided Local Agency
1
Additional Notes and Services:
*This document will become a permanent record in the case file and is discoverable. Please limit comments to logistical or service referral information. Do not reference
mental health information or personal opinion.
1
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=== Page 1 ===
United States District Court
Southern District of New York
Plaintiff,
Case No.: 15-cv-07433-RWS
V.
Ghislaine Maxwell,
Defendant.
/
PLAINTIFF'S REQUEST FOR ADMISSIONS
TO DEFENDANT GHISLAINE MAXWELL
Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Set
of Interrogatories to Defendant Ghislaine Maxwell, pursuant to Rules 26 and 36 of the Federal
Rules of Civil Procedure and Local Rule
. The responses are due at the offices of Boies,
Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1.
"Agent" shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
2.
"Correspondence" or "communication" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
1
EFTA00025469

=== Page 2 ===
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3.
"Defendant" shall mean the defendant Ghislaine Maxwell and her employees,
representatives or agents.
4.
"Document" shall mean all written and graphic matter, however produced or
reproduced, and each and every thing from which information can be processed, transcribed,
transmitted, restored, recorded, or memorialized in any way, by any means, regardless of
technology or form. It includes, without limitation, correspondence, memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telecopies, invoices, worksheets, printed matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
"writings" and "recordings" as set forth in the Federal Rules of Evidence, including but not
2
EFTA00025470

=== Page 3 ===
limited to, originals or copies where originals are not available. Any document with any marks
such as initials, comments or notations of any kind of not deemed to be identical with one
without such marks and is produced as a separate document. Where there is any question about
whether a tangible item otherwise described in these requests falls within the definition of
"document" such tangible item shall be produced.
5.
"Employee" includes a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
6.
"Including" means including without limitations.
7.
"Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein.
8.
"Massage" includes any person touching another person, and includes any person
using any object, including sex toys, to touch, another person.
9.
"Person(s)" includes natural persons, proprietorships, governmental agencies,
corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other
legal or business entity.
10.
"Sex toys" shall mean any object or device used to sexually stimulate or enhance
sexual pleasure.
11.
"You" or "Your" hereinafter means Ghislaine Maxwell and any employee, agent,
attorney, consultant, related entities or other representative of Ghislaine Maxwell.
3
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INSTRUCTIONS
1.
If you deny only a portion of a request to admit, specify in full and complete
detail: (a) the portion of the request that is denied; (b) the reasons for your denial; and (c) those
positions that are admitted as true.
2.
When an objection is made to a request to admit, specify in full the grounds for
your objection.
4
EFTA00025472

=== Page 5 ===
REQUESTS FOR ADMISSION
1.
Admit that Ross Gow was authorized by You or your agents to make statements
to the public on your behalf.
2.
Admit that Acuity Reputation was authorized by You or your agents to make
statements to the public on your behalf.
3.
Admit that Ross Gow had your approval to make the statement that he made to
the public in January of 2015.
4.
Admit that Ross Gow had your approval or your agent's approval to make the
statement that he made to the public in January of 2015.
5.
Admit that you knew or had reason to believe that Ross Gow would make a press
release addressing accusations made against you in January 2015.
6.
Admit that you knew or had reason to believe that one of your agents would cause
a press release to issue regarding
7.
Admit that you knew or had reason to believe that Ross Gow's press release
would be reported by the press.
8.
Admit that after Ross Gow issued the January 2015 statement to the public, you
took no action to retract or remediate the statement, clarify the statement, or otherwise cause a
different message to enter the public domain.
9.
Admit that you, Ross Gow, and Acuity Reputation did not have
consent to make any statements regarding
10.
Admit that having your statements be classified as "obvious lies" in the news
media is damaging to one's reputation.
5
EFTA00025473

=== Page 6 ===
11.
Admit that you asked
(then,
)
to meet Jeffrey
Epstein.
12.
Admit that you asked
(then,
) to work for Jeffrey
Epstein.
13.
Admit that Jeffrey Epstein had sex with individuals who gave him massages.
14.
Admit that you were aware that
was under the age of 18 when
you facilitated her giving massages to Jeffrey Epstein.
15.
Admit that you met
at Mar-A-Lago.
16.
Admit that you introduced
to Jeffrey Epstein.
17.
Admit that you travelled on Jeffrey Epstein's private plane with
during the year 2001.
18.
Admit that
was present at your London home in 2001 with
Prince Andrew.
6
EFTA00025474

=== Page 7 ===
Dated: May 26, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Bradley J. Edwards (Pro Hac Vice)
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(
I This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
7
EFTA00025475

=== Page 8 ===
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has
been provided by electronic mail to all counsel of record identified below, on this 26th day of
May, 2016.
Laura A. Menninger, Esq.
Jeffrey S. Pagliuca, , Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel:
Fax:
Email:
Email:
By: /s/ Sigrid McCawley
Sigrid McCawley
8
EFTA00025476


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=== Page 1 ===
From:
To:
Subject: RE: Epstein estate
Date: Wed, 08 Jul 2020 14:46:17 +0000
l'll be free then and can join.
From:
Sent: Wednesday, July 8, 2020 10:46 AM
To:
Subject: FW: Epstein estate
This works for me, and the more the merrier but also happy to handle if that's useful.
From:
Sent: Wednesday, July 08, 2020 10:44
To:
Cc:
Subject: Epstein estate
:
Would you have time for a relatively quick call today around 1:00?
Thanks,
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
I 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.
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=== Page 1 ===
From:
(NY) (FBI)"
To:
(NY) (FBI)"
Subject: Epstein status
Date: Mon, 12 Oct 2020 18:48:49 +0000
FYI. I did 5 hours on Saturday, another 3 yesterday, and have been here since 9. I have successfully exported
stuff from 41 items. I have another 8 left. They are all Macs and have been problematic. I will beat on it again
tomorrow. I was able to do the exports with 5 machines. I will be down to 2 for the remaining Mac stuff. Will
keep you posted as to how stuff goes.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: FOIA Request for Ghislaine Maxwell's Mugshot
Date: Wed, 22 Jul 2020 22:25:11 +0000
We don't have it right now, but we should be getting it soon and producing it in discovery. I'm not aware of any FOIA
exemptions that would preclude us from producing it, but those are typically handled by
CivDiv.
From:
Sent: Wednesday, July 22, 2020 4:55 PM
To:
Cc:
Subject: Re: FOIA Request for Ghislaine Maxwell's Mugshot
It's correct that SDNY doesn't have it. I don't know who the FOIA request is directed to - whether it's just to our office or
to FBI or DOJ as a whole. I think the office's practice on this case is to forward all FOIA inquiries to
who is
handling them as the main point of contact.
Sent from my iPhone
On Jul 22, 2020, at 4:46 PM,
wrote:
Isn't the answer just that we don't even have it?
Related, I just put in an intake form request (apologies if someone already did), for discovery production
From:
(USAEO)
Sent: Wednesday, July 22, 2020 16:08
To:
is
V.
Cc:
(USANYS)
Subject: FOIA Request for Ghislaine Maxwell's Mugshot
and
:
Good afternoon. I'm with the FOIA/PA Staff here in D.C., and I just received a FOIA request from someone for Ghislaine
Maxwell's "mugshot." Though I tasked this FOIA request to
,
I'm checking with you directly to see if the
photo exists and if it is releasable. I sense it's not being circulated on the internet for a reason and wanted to get the
backstory in order to respond to the request. Please feel free to let me know if this is something that should be
discussed over the phone. Thanks.
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Revised OOP
Date: Fri, 26 Nov 2021 18:49:03 +0000
Attachments: Maxwell_Order_of_Proof _v12.docx
Hey
- revised OOP attached.
EFTA00024895


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=== Page 1 ===
@SDNYNews Priorities
JUNE, 2021
Lev Parnas and Igor Fruman charged with conspiring to violate straw and foreign donor bans: In
October 2019, four defendants were charged in a four-count indictment alleging that each of
the defendants conspired to violate the ban on foreign donations and contributions in
connection with federal and state elections. In addition, Parnas and Fruman were charged with
conspiring to make contributions in connection with federal elections in the names of others,
and with making false statements to and falsifying records to obstruct the administration of a
matter within the jurisdiction of the Federal Election Commission ("FEC").
Ghislaine Maxwell charged for conspiring with Jeffrey Epstein to sexually abuse minors: In July
2020, Maxwell was arrested and charged with enticing a minor to travel to engage in criminal
sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn
deposition. The Indictment unsealed today alleges that between at least in or about 1994
through 1997, Maxwell and co-conspirator Jeffrey Epstein exploited girls as young as 14,
including by enticing them to travel and transporting them for the purpose of engaging in illegal
sex acts. As alleged, knowing that Epstein had a preference for young girls, Maxwell played a
critical role in the grooming and abuse of minor victims that took place in locations including
New York, Florida, and New Mexico. In addition, as alleged, Maxwell made several false
statements in sworn depositions in 2016.
Proposed:
Jennifer Shah (elder abuse)
Kolfage, et al.
Hadden
DPRK Boat Seizure
Nygard
Honduran Ntl Police Chief
Rikers guards smuggling to inmates?
Horseracing indictments?
EFTA00023917


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
July 20, 2020
BY EMAIL
Jason E. Foy
Foy & Seplowitz LLC
Re:
United States V. Tova Noel, No. 19 Cr. 830
Dear Mr. Foy:
We write in response to your discovery request letter, dated June 5, 2020. Many of the
items requested in your letter were previously produced to the defendant in discovery, and to the
extent they were not, that is because they were not in the Government's possession. While, as the
Court has already ruled, the Government has no obligation to gather additional documents from
the Bureau of Prisons ("BOP") in response to a discovery request, and you identify no authority to
the contrary in your request, as a courtesy, the Government made a supplemental request to the
BOP for certain records responsive to your requests and that appear to have at least some relevance
to the issues related to this case. Pursuant to that supplemental request, the BOP began producing
records to our Office on or around June 24, 2020, and we are now producing those materials to
you. This letter and the content herein is designated as "Protected Materials" pursuant to the
Protective Order entered in this matter. By contrast, as set forth herein, the Government has not
requested materials not already in its possession that do not seem to have any relevance to this
case, although we are happy to discuss the basis for any such request at your convenience.
Request No. 1. Defendant Noel's complete personnel and training file.
The Government has already produced the entirety of the defendant's training and
personnel file in its possession at SDNY_00006228-06273.
The Government received Noel's training record from the BOP on or about June 24, 2020,
and is producing it at SDNY_TN_00020855-020857.
Request No. 2. The BOP and MCC Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
On or about June 24, 2020, the Government received from the BOP copies of the BOP
Program Statement regarding Employee Code of Conduct, P.S. 3420.11; Noel's acknowledgement
form; and the U.S. Department of Justice Ethics Handbook for On and Off-Duty Conduct from
06.20.2018
EFTA00023756

=== Page 2 ===
Page 2
January 2016. We are producing those records at SDNY_00008394-08427, SDNY_TN_0020854,
and SDNY_00008352-08370 respectively.
Request No. 3. The MCC institutional familiarization training outline.
On or about June 25, 2020, the Government received from the BOP a document entitled
Introduction to Correctional Techniques from July 2019 and is producing it at SDNY_00008388-
08393.
Request No. 4. The MCC annual training outlines for 2018 and 2019.
The Government has already produced the MCC annual training outlines for 2018 and
2019 in its possession at SDNY_00005109-05129.
Request No. 5. A copy of the internal memorandums, letters, and/or emails addressing the
death of Jeffrey Epstein including, but not limited to, the memorandums drafted by Employee
Number 5, Employee Number 6, and Employee Number 13.
The Government has already produced the requested documents at SDNY_00000796-
0857. The memorandum drafted by Employee 5 is at SDNY_00000820; the memorandum drafted
by Employee 6 is SDNY_00000813; and the memorandum drafted by Employee 13 is
SDNY_00000823.
Request No. 6. The email referenced in Employee Number 7's witness statement that was
sent to MCC employees regarding Jeffrey Epstein's need for a cellmate.
The Government has already produced this email at SDNY_00008119-08122.
Request No. 7. Psychology Services post-suicide watch report drafted by Employee
Number 12 on July 24, 2019.
The Government has already produced the July 24, 2019 Psychology Services post-suicide
watch report at SDNY_00006425-06427.
Request No. 8. A copy of the memorandum sent by Employee Number 22 to the evening
watch officers stating that Jeffrey Epstein needed a cellmate.
To the extent that this request is seeking a "memo" referenced in the interview of Employee
Number 22, which was not sent by Employee Number 22, the Government has already produced
a copy of this memorandum at SDNY_00000823.
Request No. 9. The BOP and MCC policy on cellmates and local Institutional Supplement
on Special Housing Unit Regulations, including Institutional Supplement/Program Statement
Number P.S. NYM 5270.10.
06.20.2018
EFTA00023757

=== Page 3 ===
Page 3
The Government received from the BOP a copy of the BOP Program Statement regarding
Special Housing Units, P.S. 5270.11, 1 on or about June 24, 2020, and is producing it at
SDNY_00008428-08445.
According to a representative of the BOP and MCC, he is unaware of any written policy
regarding cellmates.
Request No. 10. The BOP and MCC policy on SHU quarterly training.
On or about June 24, 2020, the Government received from the BOP a copy of the BOP
Program Statement regarding Suicide Prevention, P.S. 5324.08; a PowerPoint presentation entitled
Suicide Prevention for Inmates from 2014; a PowerPoint Presentation entitled MCC SHU Training
from 2014; and the BOP Program Statement regarding Special Housing Units, P.S. 5270.11, and
is producing them at SDNY_00008446-08470, SDNY_00008338-08351, SDNY_00008554-
08585, SDNY_00008284-08337, and SDNY_00008428-08445, respectively.
Request No. 11. The Inmate Accountability Institutional Supplement/Program Statement,
Number I.S. NYM 5511.08, referenced in bates number SDNY_0005392.
The Government received from the BOP a copy of this document on or about June 24,
2020, and is producing it at SDNY_00008371-08387.
On or about June 24, 2020, the Government also received from the BOP a copy of the BOP
Correctional Services Procedures Manual, P.S. 5500.14, and is producing it at SDNY_00008471-
08553.
Request No. 12. The Security Inspections Institutional Supplement/Program Statement,
Number I.S. NYM 5500.13, referenced in bates number SDNY_0005392.
The Government received from the BOP a copy of this document on or about June 24,
2020, and is producing it at SDNY_00008586-08595.
Request No. 13. An unredacted copy of SDNY_7551.
The redactions in SDNY_00007551 are solely the interviewee's name, which has already
been provided to you on an attorney's eyes only basis. To the extent that this request refers to the
redactions on the second page of the witness interview 302, SDNY_0007552, those redactions
relate to an ongoing criminal investigation unrelated to the conduct with which Noel is charged.
Request No .14. An unredacted copy of SDNY_883.
The document produced at SDNY_0000883 is a photograph that is not redacted.
1 While you requested P.S. 5720.10, that Program Statement does not exist. Program Statement
5720.11 is the policy covering the Special Housing Unit.
06.20.2018
EFTA00023758

=== Page 4 ===
Page 4
Request No. 15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
We are continuing to work to determine whether the Government or the BOP is in
possession of any information responsive to this request.
Request No. 16. All SHU Watch Call Logs completed during Defendant Noel's
assignment to the SHU post which began on June 26, 2019.
We are continuing to work to determine whether the Government or the BOP is in
possession of any information responsive to this request.
Request No. 17. All SHU Control Center Logs completed during Defendant Noel's
assignment to the SHU post which began on June 26, 2019.
On or about June 24, 2020, the Government received SHU Log Entries for the time period
from June 26, 2019 to August 10, 2019, and is producing them at SDNY_00008596-08670.
Request No. 18. All SHU Operations Lieutenant Log Books completed during Defendant
Noel's assignment to the SHU post which began on June 26, 2019.
The Government received Lieutenant Log Books for this time period on or about June 24,
2020, and is producing them at SDNY_00008137-08283.
Request No. 19. All SHU TRUSCOPE Log Books completed during Defendant Noel's
assignment to the SHU post which began on June 26, 2019.
The Government has already produced the Truscope logs for the SHU in its possession for
the period of July 1, 2019 through August 10, 2019 at SDNY_00003701-04098. The Government
is not aware of the relevance of these logs for the earlier period in your request, and you have not
identified the relevance of such logs.
Request No. 20. All High Risk Lists reviewed during weekly SHU meetings during
Defendant Noel's assignment to the SHU post which began on June 26, 2019.
The Government received High Risk Lists for this time period on or about June 24, 2020,
and is producing them at SDNY_00008671-08695.
Request No. 21. All SHU reports and SRO reviews completed by the SHU Lieutenant
during Defendant Noel's assignment to the SHU post which began on June 26, 2019.
In response to our request to the BOP, on July 14, 2020, the Government received a SHU
weekly review report dated August 8, 2019, and is producing it at SDNY_00008696-08723.
According to a representative of the BOP, this is the only SHU report from the requested time
period that could be located.
06.20.2018
EFTA00023759

=== Page 5 ===
Page 5
Beyond what has already been and is being provided to you in discovery, the Government
is not in possession of such documents, is not under any legal obligation to obtain them, and you
have not identified any legal basis or authority for your request. Moreover, the Government is not
aware of the relevance of records for this time period to the conduct at issue in this case, and you
have not identified the relevance of such records.
Request No. 22. A copy of the BOP Master Agreement.
To the extent that this request refers to the collective bargaining agreement between the
union and the BOP, the Government is not in possession of this document, is not under any legal
obligation to obtain it, and you have not identified any legal basis or authority for your request.
Moreover, the Government not aware of the relevance of such a record to the conduct at issue in
this case, and you have not identified the relevance of such a record.
Request No. 23. All surveillance camera records, logs, and orders since June 26, 2019,
including, but not limited to, warden, captain, lieutenant, and/or supervisory personnel records of
broken or malfunctioning surveillance cameras.
The Government has already produced surveillance camera recordings and an explanation
of the surveillance camera malfunctions at MCC. To the extent this request seeks additional
materials, including materials about surveillance camera malfunctions unrelated to the events of
August 9-10, 2019, the Government is not in possession of such materials, is not under any legal
obligation to obtain them, and you have not identified any legal basis or authority for your request.
Moreover, the Government is not aware of the relevance of such records to the conduct at issue in
this case, and you have not identified the relevance of such records.
Record No. 24. All records and logs completed by the warden, lieutenant, and/or
supervisory personnel in relation to the monitoring of counts and rounds.
The Government notes, at the outset, that this request does not appear to have an applicable
time or date range. All records or logs of counts by supervisory personnel for time periods relevant
to the conduct at issue in this case were produced at SDNY_00000076-795. Additionally,
lieutenant's logs, which contain records of counts for time periods relevant to the conduct at issue
in this case, were produced at SDNY_00002201-SDNY_00002330. Finally, thirty minute round
reports, which include supervisors' signatures, for time periods relevant to the conduct at issue in
this case, were produced at SDNY_00007109-7548. To the extent this request seeks additional
materials regarding time periods unrelated to the conduct at issue in this case, the Government is
not in possession of such materials, is not under any legal obligation to obtain them, and you have
not identified any legal basis or authority for your request. Moreover, the Government is not aware
of the relevance of such records to the conduct at issue in this case, and you have not identified the
relevance of such records.
Request No. 25. All facility maintenance logs since June 26, 2019.
The Government is not in possession of these materials, is not under any legal obligation
to obtain them, and you have not identified any legal basis or authority for your request. Moreover,
06.20.2018
EFTA00023760

=== Page 6 ===
Page 6
the Government is not aware of the relevance of such records to the conduct at issue in this case,
and you have not identified the relevance of such records.
Request No. 26. All incident reports (583 and 586 forms) drafted after Jeffrey Epstein's
death.
A Form 583 incident report related to Epstein's suicide was produced at SDNY_00000796-
SDNY_00000819. To the extent this request seeks additional materials, including any Form 583
and/or Form 586 incident reports unrelated to the death of Epstein, the Government is not in
possession of them and is not under any legal obligation to obtain them, and you have not identified
any legal basis or authority for your request. Moreover, the Government is not aware of the
relevance of such records to the conduct at issue in this case, and you have not identified the
relevance of such records.
Request No. 27. A copy of the After Action Internal Report completed after the death of
Jeffrey Epstein and Board of Inquiry Report.
The Government is not in possession of this report, and the Court has already ruled that
reports generated by investigators within the BOP that are not in the possession of the Government
are not subject to disclosure. (Dkt. No. 36 at 7-8).
Request No. 28. A copy of the Suicide Reconstruction Report
The Government is not in possession of a final version of the Suicide Reconstruction
Report. As a courtesy, we have requested that the BOP provide us with a copy when the report is
complete, and we will produce that to you upon receipt.
Request No. 29. All MCC Correctional Services, Operational Reviews, and Program
Reviews relating to the SHU and completed during Defendant Noel's employment at the MCC
which began on June 24, 2018.
The Government is not in possession of these materials, is not under any legal obligation
to obtain them, and you have not identified any legal basis or authority for your request. Moreover,
the Government is not aware of the relevance of such records to the conduct at issue in this case,
and you have not identified the relevance of such records.
Request No. 30. Who is the author of the 4Chan message produced as bates number
SDNY_00006978?
The Government has produced all records we have obtained regarding the 4Chan post. The
poster used a dynamic IP, and therefore the records obtained did not disclose the author of the post.
Request No. 31. All internal and external investigation records related to the suicide of
Kenneth Houck at the MDC, death of inmate Jamel Floyd at the MDC, and smuggling of a firearm
into the MCC.
06.20.2018
EFTA00023761

=== Page 7 ===
Page 7
This Office is not in possession of materials relating to the death of Kenneth Houck and
Jamel Floyd at the MDC, is not under any legal obligation to obtain them, and you have not
identified any legal basis or authority for your request. Moreover, the Government is not aware of
the relevance of such records-which pertain to events that significantly post-date the conduct
giving rise to the charges in the Indictment-to the conduct at issue in this case, and you have not
identified the relevance of such records.
Materials relating to the smuggling of a firearm into the MCC also post-date the
defendant's arrest and have no relevance to the conduct at issue this case. Moreover, you have not
identified the relevance of such records to this case, or the basis under which they would be subject
to disclosure or discovery in this case.
We are available at your convenience to discuss anything further.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
06.20.2018
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: NY Judge Rips "Terrible' Conditions At NYC Federal Jails - Law360
Date: Wed, 06 May 2020 11:46:16 +0000
NY Judge Rips 'Terrible' Conditions At NYC Federal Jails
By Stewart Bishop
https://www.law360.com/articles/1270636/ny-judge-
Share us on:
rips-terrible-conditions-at-nyc-federal-jails
Law360, New York (May 5, 2020, 9:12 PM
EDT) -- A New York federal judge on Tuesday
derided the "unfortunate, terrible" conditions
at New York City's two main federal jails, both
before and after the coronavirus pandemic,
during a hearing where he sentenced an
admitted fraudster who tried to steal $2.5
million from a law firm to time served.
U.S. District Judge Richard M. Berman
criticized the "deficient system" at the
Metropolitan Detention Center in Brooklyn
and said he "has serious doubts" about the
ability of the Metropolitan Correctional Center
in Manhattan to safely and properly house its
detainees.
Judge Berman, who presided over the
criminal sex trafficking case against Jeffrey
Epstein until his suicide at the MCC in
August, said he was very disappointed that to
his knowledge, U.S. Attorney General William
Barr has not conducted a thorough
assessment and investigation of the Bureau
of Prisons nationwide, something he said
Barr pledged to do around the time of
Epstein's suicide.
EFTA00025383

=== Page 2 ===
In particular, Judge Berman said as far as he
knows, there have been no serious reviews
forthcoming of the poor living conditions at
either the MCC or the MDC - which he said
are dirty and infested with drugs and violence
- conditions that have been many times
compounded by the coronavirus outbreak.
"It is an outrage | have to say, and I'm very
disappointed the Attorney General has not
followed through on making a thorough
investigation of conditions that those of us in
the business, as it were, are all too familiar
with," Judge Berman said. "And more
importantly has not implemented appropriate
changes."
A spokesman for the U.S. Department of
Justice in Washington, D.C., did not
immediately respond to a request for
comment.
The judge's remarks came at the sentencing
via video and audio conference of Terrance
Morgan, who pled guilty to bank fraud
conspiracy in October for his role in a scheme
to steal $2.5 million from an unnamed law
firm's bank account.
Morgan, a citizen of Liberia and U.S. resident,
already served about 14 months in custody
with the Bureau of Prisons - including at the
MDC - Immigration and Customs
Enforcement and local authorities.
An attorney for Morgan, Sam Schmidt, said
he was pleased with Judge Berman's
EFTA00025384

=== Page 3 ===
decision.
"It is gratifying to hear that Judge Berman
fully understands what our clients are going
through in the Bureau of Prisons at this time,
especially in MCC and MDC," Schmidt said.
While Judge Berman didn't explicitly tie
Morgan's sentence of time served, three
months of home confinement and four years
of supervised release to the conditions at the
MDC, and the dangers of the coronavirus to
inmates, it appeared to be a major factor. The
judge also said while he doesn't disagree that
Morgan's crime was a serious one, he said
the goals of general and specific deterrence
have been met, and the term of incarceration
he has already served is adequate.
The judge also appeared to give some
amount of weight to an April 30 report by
Homer Venters, a physician and
epidemiologist, who toured the 1,700-inmate
facility recently to observe the jail's response
to COVID-19.
In the report, which was filed in a proposed
class action brought by medically vulnerable
inmates seeking release from the prison
because of the coronavirus, Venters
excoriated the medical care at MDC in his
expert report.
Venters, who previously served as the chief
medical officer for New York City's jails, cited
an array of problems including faulty virus
screening, ignored and discarded sick-call
requests, inept medical care and a "gross
EFTA00025385

=== Page 4 ===
deviation" from Centers for Disease
Controland Prevention and correctional
health care standards.
"I have to say it's a very serious document. It
is not surprising to me. I've personally
become acutely aware of the deficiencies at
the MDC," Judge Berman said, citing a
well-known incident in January 2019 when a
fire took out the jail's power and heat.
Inmates were left in frigid conditions for a
week and denied meetings with their
attorneys or any other visits.
That incident led to an ongoing lawsuit by the
Federal Defenders of New York against the
BOP over attorneys' access to clients in the
MDC. That case is currently in mediation,
which includes the MCC as well.
Judge Berman said Venters' report requires
that there be a response from the BOP to the
criticisms in the document.
"Such a response is long overdue," Judge
Berman said. "It was long overdue when
Jeffrey Epstein committed suicide, long
before then."
The government is represented by Dina
McLeod and Robert B. Sobelman of the U.S.
Attorney's Office for the Southern District of
New York.
Morgan is represented by Sam A. Schmidt.
The case is U.S. V. Morgan et al., case
number 1:19-cr-00209, in the U.S. District
EFTA00025386

=== Page 5 ===
Court for the Southern District of New York.
--Additional reporting by Frank G. Runyeon.
Editing by Amy Rowe.
EFTA00025387


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: JE estate meeting
Date: Tue, 31 Dec 2019 03:25:43 +0000
Following up on your request for a meeting, I think due to various holiday-related issues we don't yet have a response for
you, and wanted to provide that status given the approach of the dates you had initially mentioned as being possible. It's
our hope that once everyone in our office is back and settled next week we'll be able to circle back to you with more
information. We remain very aware of the ongoing processes on the estate / trustees side and we'll work to a response to
you as soon as possible.
thanks,
From:
Sent: Friday, December 20, 2019 17:17
To:
Cc:
Subject: RE: JE estate meeting
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
EFTA00024512

=== 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
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.
EFTA00024513


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: 20-3061 United States of America V. Maxwell "Summary Order FILED"
Date: Mon, 19 Oct 2020 18:56:29 +0000
Attachments: Maxwell_Civil_SO.pdf
And the same panel just affirmed
unsealing of Maxwell's deposition, among other documents.
From:
Sent: Monday, October 19, 2020 2:54 PM
To:
is
)
Cc:
Subject: RE: 20-3061 United States of America V. Maxwell "Summary Order FILED"
Nice!
From:
Sent: Monday, October 19, 2020 2:51 PM
To:
i
Cc:
Subject: FW: 20-3061 United States of America V. Maxwell "Summary Order FILED"
Good news - Maxwell's appeal relating to the protective order modification was dismissed on jurisdictional grounds.
Great job by the team and by Lara at oral argument.
From:
Sent: Monday, October 19, 2020 2:44 PM
To:
is
Cc:
(USANYS)
i
Subject: Fwd: 20-3061 United States of America V. Maxwell "Summary Order FILED"
Maxwell's appeal has been dismissed.
Begin forwarded message:
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
Date: October 19, 2020 at 2:35:00 PM EDT
To:
Subject: 20-3061 United States of America V. Maxwell "Summary Order 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.
EFTA00027066

=== Page 2 ===
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 10/19/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
SUMMARY ORDER AND JUDGMENT, dismissing the appeal, by JAC, RSP, RR, FILED.[2955206] [20-
3061]
Notice will be electronically mailed to:
The following document(s) are associated with this transaction:
Document Description: Summary Order FILED
Original Filename: 20-3061_so.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/19/2020] [FileNumber=2955206-0]
[c9287df390bbf83b60e39be41f91c2f0fdc321b401f2206499afb40c712331d20b0ed4d402ef2a304563e9ec9e47
7368fd7dfbee4e7c9fe40f9134601e97d0f]]
Document Description: Bill_of_Cost_Itemized_Notice_1
Original Filename:
/opt/ACECF/live/forms/YenniLiu_203061_2955206_Bill_of_Cost_Itemized_Notice_1_292.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/19/2020][FileNumber=2955206-1]
[4edda701c0a976b1a5449cc3707d8496b0a95c561bbec5d14c4f25cdc52d63b9a285c3c9ef4bf7dbc646c562a4b6
878edc16d9039d6719252fd2f737fc6b3da5]]
Recipients:
EFTA00027067

=== Page 3 ===
Document Description: Bill_of_Cost_Itemized_Notice_2
Original Filename:
/opt/ACECF/live/forms/YenniLiu_203061_2955206_Bill_of_Cost_Itemized_Notice_2_291.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/19/2020] [FileNumber=2955206-2]
[3a81f26fadf203008714022cc8285c1022e72e400c60e780d312ce3feec69400ced785abfe17d4c197c5c77b6504
bd9244b52ef24c2f0155f059bc5df2ffdbec|]
Recipients:
EFTA00027068


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: JE Release
Date: Sun, 07 Jul 2019 20:14:26 +0000
Importance: Normal
Attachments: 2019-07-04,_JE,_press_release,_draft.docx
Do you have a more recent version than the attached (sent on Wednesday)? We were going to expand the FBI thank-you
sentence to be the following:
Mr. Berman praised the outstanding investigative work of the FBI, and thanked the New York City Police Department and
Customs and Border Patrol for their assistance in the investigation.
But defer to you if you have a different preference, and let me know whether you want me to incorporate or if you guys
have the pen at this point. Thank you!
From:
Sent: Sunday, July 07, 2019 13:57
To:
Cc:
is
Subject: Re: JE Release
Nypd is a task force partner on the fbi crimes against children squad, so we have the release set up as a co-announce with
them, with a slot for an
quote, which we've asked for from dcpi. That being the case, we should acknowledge
them with the same language we use for the fbi.
Chief Public Information Officer
U.S. Attorney's Office, SDNY
(office)
(cell)
On Jul 7, 2019, at 12:37 PM,
wrote:
I might put the thank you after the FBI but before he introduces our people in the remarks. Otherwise fine with me.
if you haven't already, we should loop in
on the press conference issue. If NYPD plans to stand up I feel like
he is going to want to know that and know who is going to be there.
EFTA00026626

=== Page 2 ===
Sent from my iPhone
On Jul 7, 2019, at 12:32 PM,
wrote:
just asked me if we should thank NYPD and CBP for their assistance, and I think why not, right? The more the
merrier in terms of giving credit? He asked me to circulate a sentence for both of them, for adding to his remarks and
the press release, but wanted to circulate here first and then I can send to the brass subject to this crew's input.
Not that this is rocket science, but does this work, in the remarks after for their dedication and professionalism in
seeing this investigation through.":
I also want to thank the New York City Police Department and Customs and Border Patrol for their assistance in the
investigation.
And in the press release: "Mr. Berman praised the outstanding investigative work of the FBI, and thanked the New York
City Police Department and Customs and Border Patrol for their assistance in the investigation."
Thoughts?
Original Message
From:
Sent: Sunday, July 07, 2019 12:24
To:
Cc:
Subject: Re: JE Release
Have we heard anything yet from nypd?
Sent from my iPhone
> On Jul 7, 2019, at 12:19 PM,
wrote:
>
> Apologies if this has been asked/answered: do we need to thank the NYPD in the release and remarks? And did CBP
play any role? Just wanted to make sure we're not forgetting anyone, thanks.
>
> Sent from my iPhone
EFTA00026627


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=== Page 1 ===
From:
)"
To:
)"
)"
Cc:
]"
Subject: RE: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
Date: Fri, 31 Jul 2020 17:16:33 +0000
Hi
,
We don't have this document -- it sounds like it's an unsealed filing from a civil suit, and those filings are
voluminous, so we don't know which document that is (we're not tracking the unsealed documents).
Thanks,
Original Message
From:
)
Sent: Friday, July 31, 2020 12:45 PM
To:
)
Cc:
Subject: FW: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
Rather than ask this reporter for a copy of the doc (below), would you happen to have it? Main is asking. Thanks.
Original Message
From:
Sent: Friday, July 31, 2020 12:43 PM
To: Press
Subject: RE: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
+SDNY team. If you don't have copy of this civil litigation filing reporter is referencing, can you ask reporter for
copy of doc?
Original Message
From: no-reply@usdoj.gov <no-reply@usdoj.gov>
Sent: Friday, July 31, 2020 12:21 PM
To: Press
Subject: Media Inquiry from
- Daily Mail - Jeffrey Epstein inquiry
Date Friday, July 31, 2020 - 12:21 pm EDT
Name: Daniel Bates
Email Address:
Topic: Federal Bureau of Investigation (FBI)
Media Outlet: Daily Mail - Jeffrey Epstein inquiry
EFTA00023780

=== Page 2 ===
Deadline: ASAP
Inquiry:
Hello, I'm a journalist with the Daily mail and am looking to find out if you have any comment on the claim in
newly unsealed court documents that Prince Andrew and Alan Dershowitz put pressure on the DOJ to give
Jeffrey Epstein a favorable plea deal in 2007. The documents were unsealed in a civil case brought by
an Epstein victim, against Ghislaine Maxwell, his alleged madam. Please email or call me on
EFTA00023781


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Call
Date: Thu, 21 May 2020 13:36:16 +0000
Importance: Normal
Attachments: unnamed
EFTA00026536


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: RE:
Date: Sat, 21 Sep 2019 19:20:46 +0000
That's not your phone number.
Original Message
From:
)
Sent: Saturday, September 21, 2019 3:19 PM
To:
i
I.
Cc:
i
Subject: RE:
,
I left a message on Thursday afternoon to follow up briefly on our prior discussion-completely understand that
you're likely busy with family obligations, but wanted to make sure we connected before any next steps on your
end. Please feel free to call my cell anytime (including this weekend if that's preferable),
thanks,
Original Message
From:
Sent: Thursday, September 19, 2019 14:29
To:
I.
Cc:
Subject: Re:
Sorry. Lost you at the very end. Thank you for your time and we appreciate your consideration. We look forward
to rescheduling our meeting.
Partner
<x-apple-data-detectors://2/1><x-apple-data-detectors:/4/1
Bio<
VCard<http://www.winston.com/vcards/1022.vcf> I Email<mailto:
EFTA00025355

=== Page 2 ===
winston.com<http://www.winston.com/>
On Sep 19, 2019, at 1:53 PM,
I.
<mailto:
wrote:
Great, thank you.
Associate Attorney
m
Original Message
From:
)
<mailto:
Sent: Thursday, September 19, 2019 1:48 PM
To:
I.
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
We will be available for about 10 minutes at 2:15 and will dial in then. To the extent we can cover any of these
topics more thoroughly on Monday, that's our preference, but we'll call in at 2:15. Thanks.
Sent from my iPhone
On Sep 19, 2019, at 13:41,
I.
<mailto:
wrote:
Apologies for the multiple emails, 2:15 pm actually works better on our end. Thanks again.
Associate Attorney
Original Message
From:
I.
Sent: Thursday, September 19, 2019 1:38 PM
To:
)'
<mailto:
EFTA00025356

=== Page 3 ===
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
,
We can do a call at 2 pm. We can use the call-in number below. We'd like to discuss our meeting on Monday, one
of the recently filed cases, and press inquiries. Thanks.
Dial in:
Passcode:
Associate Attorney
http://www.winston.com
Original Message
From:
)
<mailto:
Sent: Thursday, September 19, 2019 12:06 PM
To:
I.
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
We have a number of meetings today-I believe we could do a call anytime up until 2:30 pm, and then likely not
again until approximately 8 pm or later, but both subject to confirmation with the team. We're also relatively free
tomorrow. Could you give us a sense of the topic and the urgency?
Sent from my iPhone
On Sep 19, 2019, at 10:25,
I.
<mailto:
wrote:
Hi all,
Are you available for a call today at 4:30 pm?
Thanks,
Associate Attorney
EFTA00025357

=== Page 4 ===
New York, NY 10166-4193
D:
F:
Original Message
From:
)
<mailto:
Sent: Sunday, August 25, 2019 5:28 PM
To:
<mailto:
Cc:
<mailto:
<mailto:
)
<mailto:
I.
<mailto:
Subject: RE:
That would be perfect, thank you very much. We'll plan for 9/6 at 2:30pm.
Assistant United States Attorney
Southern District of New York
<mailto:
Original Message
From:
<mailto:
Sent: Saturday, August 24, 2019 5:38 PM
To:
<mailto:
Cc:
<mailto:
<mailto:
)
<mailto:
I.
<mailto:
Subject: Re:
Yes - we can do the afternoon of 9/6. Would 2:30 pm work for you?
Partner
<x-apple-data-detectors://2/1><x-apple-data-detectors://4/1>
EFTA00025358

=== Page 5 ===
Bio
VCard<http://www.winston.com/vcards/1022.vcf I Email<mailto:
winston.com<http://winston.com><http://www.winston.com/>
On Aug 23, 2019, at 4:42 PM,
<mailto:
<mailto:
wrote:
Apologies for the scheduling difficulties--unfortunately none of your proposed dates will work for us. Any
chance you'd be available on 9/6? We are flexible that whole day.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
<mailto:
Original Message
From:
<mailto:
<mailto:
Sent: Thursday, August 22, 2019 10:14 PM
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
I.
<mailto:
<mailto:
Subject: Re:
Unfortunately, we aren't available on 8/26. How about 8/28? If that doesn't work, we can also do the afternoon
of 9/3 or the afternoon of 9/4. Please let me know what works best for you.
Thanks,
Partner
EFTA00025359

=== Page 6 ===
<x-apple-data-detectors://2/1><x-apple-data-detectors://4/1>
Bio
VCard<http://www.winston.com/vcards/1022.vcf I Email<mailto:
winston.com<http://winston.com><http://winston.com><http://www.winston.com/>
On Aug 22, 2019, at 1:47 PM,
)
<mailto:
<mailto:
<mailto:
^
wrote:
,
Very sorry for another rescheduling request, but we just had some changes to our schedules for 8/27. Is there any
way that we could meet on the afternoon of 8/26 instead? We are available from 2pm to 5pm if that works for
you.
Thanks very much,
Assistant United States Attorney
Southern District of New York
<mailto:
<mailto:
<mailto:
Original Message
From:
)
Sent: Monday, August 19, 2019 2:21 PM
To:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
I.
<mailto:
<mailto:
<mailto:
Subject: RE:
That works for us. See you then.
EFTA00025360

=== Page 7 ===
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
<mailto:
<mailto:
Original Message
From:
<mailto:
<mailto:
<mailto:
Sent: Monday, August 19, 2019 12:49 PM
To:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
I.
<mailto:
<mailto:
<mailto:
Subject: Re:
That would be fine. How about 1 pm on August 27th?
Partner
<x-apple-data-detectors://2/1><x-apple-data-detectors://4/1>
Bio<
VCard<http://www.winston.com/vcards/1022.vcf> I Email<mailto:
winston.com<http://winston.com><http://winston.com><http://winston.com><http://www.winston.com/>
On Aug 19, 2019, at 10:50 AM,
)
EFTA00025361

=== Page 8 ===
<mailto:
<mailto:
<mailto:
<mailto:
wrote:
,
Turns out
will be travelling on the 28th. Would it be possible to plan for the 27th instead?
and I are
both available any time before 5pm on that 27th and happy to meet.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
<mailto:
<mailto:
<mailto:
Original Message
From:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Saturday, August 17, 2019 4:30 PM
To:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
I.
<mailto:
mailto:
<mailto:
<mailto:
Subject: Re:
Yes. That's fine. What time would be best for you? Thanks.
Partner
<x-apple-data-detectors://2/1><x-apple-data-detectors://4/1>
EFTA00025362

=== Page 9 ===
Bio
VCard<http://www.winston.com/vcards/1022.vcf | Email<mailto:
winston.com<http://winston.com><http://winston.com><lhttp//winston.com><http//winston.com>
<http://www.winston.com/>
On Aug 17, 2019, at 2:02 PM,
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
wrote:
,
I think it's unlikely the trial will be quite that brief, but if you're not available later that week, we can schedule it
for the 28th and at least one or both of
and
will be able to attend. Would you be able to do late
afternoon?
thanks,
Original Message
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Friday, August 16, 2019 08:23
To:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
I.
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
- Thank you for your prompt response. We will advise our client accordingly.
As for scheduling, can we plan for August 28 with the hope that your trial will be over by then (or perhaps will
be in jury deliberations such that you can get away for a meeting)? If it turns out that your trial isn't over by then,
perhaps we can still meet with
and
that day. Please let us know if that would work.
Many thanks,
On Aug 16, 2019, at 12:48 AM,
<mailto:
<mailto:
<mailto:
EFTA00025363

=== Page 10 ===
<mailto:
<mailto:
<mailto:
wrote:
,
First, and most importantly, to the extent your client or any of her family, friends, loved ones, etc., feel
threatened by any communications or other actions, they should not hesitate to immediately report that to
authorities, whether local police, the local FBI office, and/or any other appropriate law enforcement. If your
client or anyone else believes at any time that they may be in imminent danger, they should immediately call
911. Their reporting threats to authorities will not interfere with or otherwise impact our investigation and we in
no way want to impede any legal steps they wish to take to ensure their safety. Please let us know if you have
any questions about this at all, as we do not want there to be any confusion or miscommunication about the
importance of individuals being able to ensure their safety.
Regarding a follow-up meeting, I unfortunately have a short trial starting August 26. Would it be possible to
meet sometime this coming week, rather than the following? I expect we also could make ourselves available on
a weekend day if that would be helpful, or we could set a time later in the week of the 26th. Or if none of that
works, please let us know and we'll further confer internally about options.
thank you,
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Thursday, August 15, 2019 15:15
To:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
I.
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
- Thanks for your time on the phone yesterday. Please let us know if you are available to meet on Monday,
August 26, or Tuesday, August 27, to continue our discussions and attorney proffer.
Also, I know you had limited time yesterday (and apologies for going over my initial estimate for the call), but
one of the things I had intended to share with you are some of the threatening communications that have been
received by
husband. Attached is an example of a recent one. We don't want to do anything that may
impact your ongoing investigation, so defer to you as to what should be done with respect to this.
Thanks and we look forward to hearing from you as to your availability for a meeting.
Best,
EFTA00025364

=== Page 11 ===
Partner
New York, NY 10166-4193
Bio
/Card<http://www.winston.com/vcards/1022.vcf> I Email<mailto:
winston.com<http://winston.com><http://winston.com><http://winston.com><http://winston.com>
<http://winston.com><http://www.winston.com>
<image001.jpg>
From:
)
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, August 13, 2019 8:27 PM
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
Okay, we'll call you at 2:30 tomorrow. Thanks.
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, August 13, 2019 20:23
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
EFTA00025365

=== Page 12 ===
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
I think that for purposes of tomorrow, 20 minutes should be fine. Thanks.
Partner
New York, NY 10166-4193
D:
Bio
VCard<http://www.winston.com/vcards/1022.vcf> I Email<mailto:
winston.com<http://winston.com><http//winston.com><http//winston.com><http://winston.com>
<http://winston.com><http://www.winston.com>
<image001.jpg>
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, August 13, 2019 8:21 PM
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject:
,
We have obligations at 3:00, so if you think our conversation is likely to take 20 minutes or less, we can do 2:30,
otherwise to give ourselves sufficient time we would prefer to do anytime 5:00 or later tomorrow or anytime at
all on Thursday.
thanks,
EFTA00025366

=== Page 13 ===
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, August 13, 2019 20:16
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
Subject: RE:
Can we do 2:30?
Partner
New York, NY 10166-4193
Bio
VCard<http://www.winston.com/vcards/1022.vcf Email<mailto:
winston.com<http://winston.com><http://winston.com><http//winston.com><http://winston.com/
<http://winston.com><http://www.winston.com>
<image001.jpg>
From:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
Sent: Tuesday, August 13, 2019 6:22 PM
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
EFTA00025367

=== Page 14 ===
<mailto:
<mailto:
Subject: RE:
Unfortunately we're a little over-scheduled tomorrow - we could do 2:00 tomorrow, or after 5:00. Alternatively,
we could do any time on Thursday. What would you prefer?
thanks,
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, August 13, 2019 17:34
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
Actually - I mistyped. How is 12:15?
Partner
New York, NY 10166-4193
Bio
VCard<http://www.winston.com/vcards/1022.vcf I Email<mailto:
winston.com<http://winston.com><http//winston.com><http//winston.com><http://winston.com>
<http://winston.com><http://www.winston.com>
<image001.jpg>
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, August 13, 2019 4:24 PM
To:
)
<mailto:
EFTA00025368

=== Page 15 ===
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: R
Are you available for a call tomorrow at 12:45? If so, we will send a dial in. Many thanks.
Partner
<x-apple-data-detectors://0/1>
New York, NY 10166-4193<x-apple-data-detectors://0/1>
Bio
VCard<http://www.winston.com/vcards/1022.vcf> | Email<mailto:
winston.com<http://winston.com><http:/winston.com><http://winston.com><http://winston.com>
<http://winston.com><http://www.winston.com/>
On Jul 30, 2019, at 1:54 PM,
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
wrote:
,
We should all be around, but for convenience you can have security let me know when you arrive. Looking
forward to speaking with you both at 9:30 tomorrow.
thanks,
Original Message
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Tuesday, July 30, 2019 13:22
To:
<mailto:
<mailto:
<mailto:
<mailto:
EFTA00025369

=== Page 16 ===
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
,
I am writing to confirm our meeting with you tomorrow at 9:30 a.m. Whom should we ask for when we arrive?
Thank you,
Associate Attorney
D: +1
Pronouns: she, her, hers
Please consider the environment before printing this e-mail.
Original Message
From:
)
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Wednesday, July 24, 2019 2:32 PM
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
,
Following up on the below and our brief conversation this afternoon, you're absolutely correct that I had said
we'd send transcripts of the court proceedings thus far; they are attached.
EFTA00025370

=== Page 17 ===
You also had asked about additional information about written or otherwise recorded messages from (or in
connection with, or referencing) victims. While we're not currently in a position to provide additional detail
about those particular records (in terms of identifying information on those records themselves), we can give you
related information that is more specific and I think may be more helpful. Separate from the messages, we have
contemporaneous telephone records, including records from a cell phone that was registered to your client, in her
name those cell phone records reflect numerous phone contacts with multiple girls who were underage at the
time of the calls.
thank you,
Original Message
From:
)
Sent: Tuesday, July 23, 2019 14:55
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: RE:
,
Following up on our conversations last week and yesterday, and in response to your email, we are available to
meet with you and
next week.
As we covered on the phone yesterday, you should feel free to reach out to any of us on the team if you have any
questions as you meet with your client, and thank you in advance for copying all of our team on email
communications, as we also discussed. I think I also said that we would send you the docket numbers of the
primary civil cases, which are 15 Civ. 7433 (RWS) (SDNY), 17 Civ. 616 (JGK) (SDNY), and 08 Civ. 80736
(SDFL) (the CVRA litigation). I believe there are also a number of docketed civil cases involving Mr. Epstein in
federal court in Florida, and there may also be additional state cases.
Separately, I don't recall if I said we would send this, but in case it is useful for your consideration, attached is an
example of our standard proffer agreement.
In terms of scheduling, next week we are available at 2:30 on Monday; anytime on Tuesday except for 12:30 to
1:30; and at either 9:30 a.m. or 5:00 p.m. on Wednesday, due to a court conference and other meetings during the
day.
Please let us know if we're forgetting anything or if any additional information would be useful, and we look
forward to being in touch soon.
EFTA00025371

=== Page 18 ===
Original Message
From:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Sent: Monday, July 22, 2019 12:32
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Subject:
Hi
Thank you again for your time on the phone last week. I'm following up on our conversation. First, I'm
writing to confirm that we have now been formally retained in connection with the above-referenced matter.
Second, we are available to meet with you on July 29 at 2 pm. Please let us know whether that date and time
works for you.
We look forward to hearing back from you regarding the above. Many thanks.
Best,
Partner
<x-apple-data-detectors//2/1><x-apple-data-detectors://4/1>
<x-apple-data-detectors://0/1>
New York, NY 10166-4193<x-apple-data-detectors.//0/1>
Bio<
VCard<http://www.winston.com/vcards/1022.vcf I Email<mailto:
winston.com<http://winston.com><http://winston.com><http://winston.com><http://winston.com>
<http://winston.com><http://winston.com><http://www.winston.com/>
The contents of this message may be privileged and confidential. If this message has been received in error,
please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege.
Please do not disseminate this message without the permission of the author. Any tax advice contained in this
email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under
applicable tax laws and regulations.
EFTA00025372

=== Page 19 ===
Partner
<*x-apple-data-detectors//2/1><x-apple-data-detectors://4/1>
<x-apple-data-detectors://0/1>
New York, NY 10166-4193<x-apple-data-detectors://0/1>
Bio<
VCard<http://www.winston.com/vcards/1022.vcf> I Email<mailto:
winston.com<http://winston.com><http://winston.com><http://winston.com><http://winston.com>
<http://winston.com><http://www.winston.com/>
EFTA00025373


c1: EFTA00024515
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024515.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: Page Six: Ghislaine Maxwell's powerful contacts protecting her in safe houses
Date: Thu, 02 Jan 2020 18:29:09 +0000
https://pagesix.com/2020/01/01/ghislaine-maxwells-powerful-contacts-protecting-her-in-safe-houses/
I'm sure you've seen this already. Totally just FWIW - NBC has heard that she's staying in Colorado with wealthy ex-
associates of Epstein.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
EFTA00024515


c1: EFTA00024174
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024174.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Jeff
Pagliuca
>, Laura Menninger
>,
Christian Everdell
'BOBBI C STERNHEIM'
,
Subject: US V. Maxwell, 20 CR 330 (AJN) - Government Opposition to Defense Motions in Limine
Date: Tue, 26 Oct 2021 03:58:21 +0000
Attachments: Govt_Exhibit_B.pdf; Govt_Exhibit_A.pdf;
Govt_Omnibus_Opp_[Proposed_Redactions].pdf; Govt_Omnibus_Opp_[Unredacted].pdf
Good evening,
Attached please find the Government's opposition to the defense's motions in limine in the above-captioned case.
Pursuant to the Court's order, the Government will file a redacted version on the public docket on Friday, October 29.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00024174


c1: EFTA00026621
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026621.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: State of the Office
Date: Sat, 30 May 2020 20:07:21 +0000
Attachments: SOTO - PCU - 2020.docx
I put something together modeled off what we did last year. Feel free to add/subtract, particularly if I missed anything
significant.
EFTA00026621


c1: EFTA00025271
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025271.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Maxwell Appeal
Date: Fri, 02 Oct 2020 01:33:09 +0000
Embedded: RE:_Maxwell_Appeal.msg
Sender:
Subject: RE: Maxwell Appeal
Message-Id:
<SN5P110MB0336C12BC3113EBE104D2E128A310@SN5P110MB0336.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
Cc:
Cc:
EFTA00025271


c1: EFTA00024396
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024396.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: 2020-12-16 GM renewed bail motion opposition FINAL.docx
Date: Wed, 16 Dec 2020 22:26:37 +0000
Attachments: 2020-12-16_GM_renewed_bail_motion_opposition_FINAL.docx
Not important, but I saw a quick few nits in here (one missing word and some formatting). If there is anything I can do to
help, please let me know. I'm out of pocket from 7:15 to 8:15 but am available otherwise.
EFTA00024396


c1: EFTA00024843
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024843.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B4
Evidence
31E-MM-108062 - 1B4
Item:
Evidence
General
Type:
(U//FOUO) One box containing: 1) WHITE PAPER A. PBPD 05-381(1) 2) WHITE PAPER JET BLUE RECEIPT
(2) 3) WHITE PAPER JU. (3) 4) WHITE PAPER JO. (4) 5) MESSAGE M.H. (5) 6) WHITE PAPER H. S. (6) 7)
WHITE PAPER A. (7) 8) WHITE PAPER J.S. (8) 9) WHITE PAPER H. (9) 10) WHITE PAPER ST. BARTHS (10)
Description: 11) MESSAGE - G. (11) 12) MESSAGE - J.L
(12) 13) WHITE PAPER - F. (13) 14)
MESSAGE S. (14) 15) MESSAGE - J.L. (15) 16) MESSAGE J.L. GIRL (16) 17) WHITE PAPER - S. (17) 18)
WHITE PAPER #S (18) 19) WHITE PAPER - J. (19) 20) WHITE PAPER J. (20) 21) WHITE PAPER (917) (21)
22) WHITE PAPER D.M. (22) 23) PHONE # PRINT OUT (23)
Location:
E03707388 - ECR8
E4640430 - ECR8, 14
Barcode:
E6516714
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery Location
Holding Office: NY NEW YORK
Area:
Unavailable in data migrated from
Finalized By:
II
ACS
Last Inventory: 07/20/2021 12:00 AM
Seizing Individual:
None
Other Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Il
Retention
Retention: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
Collected From:
(U//FOUO) DET.
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
Receipt Given:
No
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/2
EFTA00024843

=== Page 2 ===
7/20/2021
FD-1087
Holding Office:
MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
2/2
EFTA00024844

=== Page 3 ===
Chain of Custody FD-192
E6526714
Case ID : 31E-MM-108062
1B4
Barcode
E4229231
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
Printed Name:
Signature: jgld
Reason:
STORAGE.
Date/Time: 2-8-08
330PM
Accepted By:
Printed Name: BAYARDO L. RAMOS
RELEASED To SA.
Signature: you-
Reason:
Date/Time: 4-10-08
1100AM.
Accepted By:
Printed Name:
Signature:
Reason: Review
Date/Time: 04/10/2008 1101am
Accepted By:
Printed Name:
Signature:
Reason: Returnd all. 1Bs
Date/Time: 01/13/2009 314Pm
Accepted By:
Printed Name:.
Signature: ala
Reason: STONAGE.
Date/Time: 01-13-09
315PM
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Accepted
Reason: Reason: Reason: By: By: Name: Name: R F Signature: Signature: Date/Time: Date/Time: Date/Time:
Printed
RF
6/14/19
Accepted
Printed
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
EFTA00024845

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Fedex:478344676408 Custody
Date and
Accepted Custody
Signature:
6/17/19
Printed Name/Agency: CMO
Date and
Time
Time
Signature:
Printed Name/Agency: Rashida Fofana
FBI
6/18/19
9:35
Reason: Transferred to NY
am
Reason:
Relinquished Custody
Date and
Accepted Custody
2:36 Date and
Time
Time
Signature:
6/18/19
Signature
6/18/19
Printed Name/Agency: Co
Printed Name/Agency
Reason:
3:115A
Reason: Evidence Review
3:45p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Signature: Printed all Name/Agency:
Time
Signat
9/26/19
Printed Name/Agency
FBI
9/26/19
Reason: Storack
2:20p
Reason; Chiza
220pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 4
Barcode:
-
E6516714
This form is incomplete without reference to the FD-1087.
EFTA00024846


c1: EFTA00024431
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=== Page 1 ===
From:
)"
To:
N. (NY) (FBI)"
Cc:
)"
)"
Subject: FW: Jeffrey Epstein consultation fees
Date: Tue, 27 Aug 2019 22:22:40 +0000
Attachments: Phone_Bill.pdf; DavidR_Passport.jpeg; DavidR_Birth_certificate.jpeg;
Dad_death_certificate.jpeg
FYI
From:
(USANYS)
Sent: Tuesday, August 27, 2019 4:57 PM
To:
is
is
Subject: FW: Jeffrey Epstein consultation fees
From: David Rowlands
Sent: Monday, August 26, 2019 2:44 PM
To
(USANYS)
Subject: Jeffrey Epstein consultation fees
Dear Madam,
My late father John Kendall Rowlands was an art historian and art collector. He assisted Jeffrey Epstein in
sourcing and disposing of works of art and may very well have loaned items to him as well. I understand that
Jeffrey Epstein owed him a substantial sum of money in consultation fees in relation to works of art and that I
would therefore have a claim on the estate in consideration of this.
My father did mention in passing the presence of young girls with Jeffrey Epstein and had he not sadly died I
expect my father would have reported his concerns to the relevant authorities
I need to communicate with the US Attorney Geoffrey Berman in charge of the case against Jeffrey Epstein - can
you therefore please pass this information on to him. My postal address is:-
David Rowlands
Email:-
Tel
EFTA00024431

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I attach scans of my passport, birth certificate and my father's death certificate along with my most recent
phonebill as proof of my address and identity / connection.
Yours faithfully,
David Rowlands
EFTA00024432


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 1 of 5
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 9/2/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
MEMORANDUM
Defendant.
OPINION AND ORDER
ALISON J. NATHAN, District Judge:
On August 17, 2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking
an Order modifying the protective order in this case.¹ Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials ("Documents") that
she received in discovery from the Government in this case. She also sought permission to
I This Order will not refer to any redacted or otherwise confidential information, and as a result it will not be sealed.
The Court will adopt the redactions to Defendant's August 17, 2020 letter motion that the Government proposed on
August 21, 2020, and it will enter that version into the public docket. The Court's decision to adopt the
Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch V.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common law presumption of access to
the materials; and (iii) balance competing considerations against the presumption of access. Id. at 119-20. "Such
countervailing factors include but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United States V. Amodeo, 71 F.3d 1044,
1048 (2d Cir.1995) ("Amodeo II")). The Government's proposed redactions satisfy this test. First, the Court finds
that the defendant's letter motion is "relevant to the performance of the judicial function and useful in the judicial
process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United
States V. Amodeo ("Amodeo "), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law
presumption of access attaches, thereby satisfying the second element. But in balancing competing considerations
against the presumption of access, the Court finds that the arguments the Government has put forth-including,
most notably, the threat that public disclosure of the redacted sections would interfere with an ongoing grand jury
investigation-favor the Government's proposed narrowly tailored redactions.
In light of this ruling, the parties are hereby ORDERED to meet and confer with respect to proposed redactions to
the Defendant's reply letter, dated August 24, 2020 and the Defendant's August 24, 2020 letter addressing her
proposed redactions to the Defendant's August 17, 2020 letter motion. The parties are further ORDERED to submit
their proposed redactions no later than September 4, 2020; if the parties cannot agree on their proposed redactions,
they shall submit a joint letter to the Court explaining the nature of their dispute.
1
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=== Page 2 ===
Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 2 of 5
reference, but not file, other discovery material that the Government produced in this case. For
the reasons that follow, Defendant's requests are DENIED.
Under Federal Rule of Criminal Procedure 16(d)(1), a Court may enter a protective order
only after it finds that good cause exists. Within this framework, the Federal Rules of Criminal
Procedure leave it to the discretion of the Court to determine whether modification of an existing
protective order is warranted.² To make that decision, the Court takes into account all relevant
factors, including the parties' reliance on the protective order and whether the moving party has
sufficiently substantiated a request to deviate from the status quo in the instant matter.
On July 30, 2020, this Court entered a protective order in this case, having determined
that good cause existed. Dkt. No. 36. The parties agreed that a protective order was warranted.
See Dkt. No. 35 at 1 ("The parties have met and conferred, resolving nearly all the issues relating
to the proposed protective order."). The Defendant's Proposed Protective Order included a
provision that stated that all discovery produced by the Government "[s]hall be used by the
Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and
not for any civil proceeding or any purpose other than the defense of this action." Dkt. No. 29,
Ex. A 1 1(a). That language was included in the Court's July 30, 2020 protective order. See Dkt.
No. 36 " 1(a), 10(a), 14(a). Shortly thereafter, the Government began to produce discovery.
Upon receipt of some of the discovery, the Defendant filed the instant request, which
seeks modification of the protective order in order to use documents produced in the criminal
2 In the civil context, there is a "strong presumption against the modification of a protective order." In re Teligent,
Inc., 640 F.3d 53, 59 (2d Cir. 2011) (citation omitted). Courts in the Second Circuit have applied the standard for
modification of protective orders in the civil context to the criminal context. See, e.g., United States V. Calderon,
No. 3:15-CR-25 (JCH), 2017 WL 6453344, at *2 (D. Conn. Dec. 1, 2017) (applying the civil standard for the
modification of a protective order in a criminal case); United States V. Kerik, No. 07-CR-1027 (LAP), 2014 WL
12710346 at *1 (S.D.N.Y. July 23, 2014) (same). See also United States V. Morales, 807 F.3d 717, 723 (5th Cir.
2015) (applying the standard for "good cause" in the civil context when evaluating whether to modify a protective
order entered in a criminal case); United States V. Wecht, 484 F.3d 194, 211 (3rd Cir. 2007) (same).
2
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Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 3 of 5
case in other civil proceedings. She bases her request on the premise that disclosure of the
Documents to the relevant judicial officers is allegedly necessary to ensure the fair adjudication
of issues being litigated in those civil matters. But after fourteen single-spaced pages of heated
rhetoric, the Defendant proffers no more than vague, speculative, and conclusory assertions as to
why that is the case. She provides no coherent explanation of what argument she intends to
make before those courts that requires the presentation of the materials received in discovery in
this criminal matter under the existing terms of the protective order in this case. And she
furnishes no substantive explanation regarding the relevance of the Documents to decisions to be
made in those matters, let alone any explanation of why modifying the protective order in order
to allow such disclosure is necessary to ensure the fair adjudication of those matters. In sum, the
arguments the Defendant presents to the Court plainly fail to establish good cause. The
Defendant's request is DENIED on this basis.
Indeed, good cause for the requested modification of the protective order is further
lacking because, as far as this Court can discern, the facts she is interested in conveying to the
judicial decisionmakers in the Civil Cases are already publicly available, including in the
Government's docketed letter on this issue. See Dkt. No. 46. In the opening paragraph of her
reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose
under seal to certain judicial officers the following factual information:
1. Grand jury subpoenas were issued to an entity ("Recipient") after the Government
opened a grand jury investigation into Jeffrey Epstein and his possible co-
conspirators;
2. The Recipient concluded that it could not turn over materials responsive to the grand
jury subpoena absent a modification of the civil protective orders in the civil cases;
3
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=== Page 4 ===
Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 4 of 5
3. In February 2019, the Government, ex parte and under seal, sought modification of
those civil protective orders so as to permit compliance with the criminal grand jury
subpoenas;
4. In April 2019, one court ("Court-1") permitted the modification and, subsequently,
another court ("Court-2") did not;
5. That as a result of the modification of the civil protective order by Court-1, the
Recipient turned over to the Government certain materials that had been covered by
the protective order; and
6. That the Defendant learned of this information (sealed by other courts) as a result of
Rule 16 discovery in this criminal matter.
With the exception of identifying the relevant judicial decision makers and specific civil
matters, all of the information listed above is available in the public record, including in the letter
filed on the public docket by the Government on this issue. See Dkt. No. 46. Although this
Court remains in the dark as to why this information will be relevant to those courts, so that
those courts can make their own determination, to the extent it would otherwise be prohibited by
the protective order in this matter, the Court hereby permits the defendant to provide to the
relevant courts under seal the above information, including the information identifying the
relevant judicial decision makers and civil matters.
In addition, the Government has indicated that "there is no impediment to counsel
making sealed applications to Court-1 and Court-2, respectively, to unseal the relevant
materials." Dkt. No. 46 at 3 n.5. In her reply, the Defendant asserts that she is amenable to such
a solution if the Court agrees with the Government that doing so would not contravene the
protective order in this case. To the extent it would otherwise be prohibited by the protective
4
EFTA00026708

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 51 Filed 09/02/20 Page 5 of 5
order in this matter, the Defendant may make unsealing applications to those Courts if she
wishes.
so ORDERED.
Alim D. Netto
Dated: September 2, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
5
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=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 29, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No.
)
MDC Brooklyn
Metropolitan Detention Center
P.O. Box 329002
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed are discovery materials and Government Exhibits pertinent to the following inmate:
Ghislaine Maxwell:
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
s/
Assistant United States Attorneys
Enclosure
EFTA00025166


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Fwd: WSJ News Alert: Jeffrey Epstein Found Dead in Jail, Officials Say
Date: Sat, 10 Aug 2019 14:05:38 +0000
In case you didnt see it -
Sent from my iPhone
Begin forwarded message:
From: "The Wall Street Journal."
Date: August 10, 2019 at 9:40:12 AM EDT
To:
Subject: WSJ News Alert: Jeffrey Epstein Found Dead in Jail, Officials Say
Reply-To:
Trouble viewing this email? View in web browser )
The Wall Street Journal.
NEWS ALERT
Jeffrey Epstein Found Dead in Jail, Officials Say
Financier Jeffrey Epstein has been found dead in jail while awaiting trial on
sex-trafficking charges, law enforcement officials said.
See More Coverage
>
I'm
Share this email with a friend.
Forwarded this email by a friend?
Forward
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Advertisement
EFTA00024347

=== Page 2 ===
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All Rights Reserved.
EFTA00024348


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=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
Cc:
Subject: SDNY PRESS GUIDANCE | U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26,
2021
Date: Fri, 26 Nov 2021 15:24:40 +0000
Importance: High
Attachments: 11-23-21_Trial_logistics_order.pdf
Inline-Images: image001.png
Before circulating this shortly, just wanted to check to see if any other orders or info worth including have
happened between Wednesday and today? Thanks!
-
-
DEP ENITED QUI PRO DOMINA JUSTITIA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
PRESS GUIDANCE
Friday, November 26, 2021
-
*ADDITIONAL OFF-THE-RECORD GUIDANCE: Please note the Court has ruled that several of the
government's witnesses, who are not alleged victims themselves, may testify under pseudonyms because the
disclosure of their identities would ostensibly reveal the identities of the alleged victims. I believe most, if not
all, news media outlets have a policy against identifying sex crime victims without their consent, and again
urge you to abide by that policy with our witnesses and respect their privacy.
If convicted, Ghislaine Maxwell faces the following statutory maximum penalties; however, her sentence would
ultimately be at the sole discretion of the judge:
Count One: conspiracy to entice a minor to travel to engage in illegal sex acts, which
carries a maximum sentence of five years in prison;
Count Two: enticing a minor to travel to engage in illegal sex acts, which carries a
maximum sentence of five years in prison;
Count Three: conspiracy to transport a minor with the intent to engage in criminal
sexual activity, which carries a maximum sentence of five years in prison;
EFTA00024892

=== Page 2 ===
Count Four: transporting a minor with the intent to engage in criminal sexual activity,
which carries a maximum sentence of 10 years in prison;
Count Five: conspiracy to commit sex trafficking of minors, which carries a statutory
maximum of 40 years in prison; and
Count Six: sex trafficking of minors, which carries a statutory maximum of five years in
prison.
A trial logistics order from Judge Nathan is also attached.
UNITED QUI PRO DOMINA JUSTITIA OF TOWNEY JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
PRESS GUIDANCE
Tuesday, November 23, 2021
*OFF-THE-RECORD. AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses
will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion
[attached] requesting that they be able to do so, because the victim witnesses are expected to describe alleged
sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of which
they have been victims. I believe most, if not all, news media outlets have a policy against identifying sex
crime victims without their consent, and urge you to abide by that policy with our witnesses and respect their
privacy.
9:30 a.m. — Final pretrial conference U.S. V. Ghislaine Maxwell - the defendant is charged in connection to
conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity - before Judge
Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood
Marshall U.S. Courthouse]).
EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable
to access this link to the file share (USAFx), you must establish an account to access the files. To establish an
account, request access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Monday, November
29, 2021.
Please also note that all case filings in U.S. V. Maxwell are available in the Court's electronic filing system; we
encourage media representatives to establish a free PACER account, if they have not done so already.
Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District
Executive's Office.
Periodic updates to follow.
EFTA00024893

=== Page 3 ===
Follow us on Facebook | Follow us on Twitter | SDNY website | YouTube
*** FOR PLANNING PURPOSES ONLY ***
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS
OFFICE AT (212) 637-2600.
EFTA00024894


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=== Page 1 ===
From:
"
To:
Cc:
Subject: Apollo Board Panel to Review Leon Black Ties With Jeffrey Epstein - The Wall Street Journal.
Date: Wed, 21 Oct 2020 00:45:59 +0000
I thought you would be interested in the following story from The Wall Street Journal.
Apollo Board Panel to Review Leon Black Ties With Jeffrey Epstein
Download the Wall Street Journal app here: WSJ.
Sent from my iPhone
EFTA00025507


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
January 10, 2021
By Electronic Mail
Christian Everdell, Esq.
Bobbi Sternheim, Esq.
Mark Cohen, Esq.
Law Offices of Bobbi C. Sternheim
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
We write in response to your letter of December 28, 2020, in which you request a bill of
particulars in the above-captioned matter. As set forth herein, the Government does not intend to
provide further particulars because under the well-established law of this Circuit it has no
obligation to do so. To the contrary, and as you are aware, the Government outlined its charges
against your client in a detailed speaking superseding indictment (the "Indictment") and has since
provided considerable additional information through the production of to date of over 2.7 million
items of discovery, all in electronic form and accompanied by an index. Accordingly, the
Government has more than provided the defendant with adequate notice of the charges against her,
and no further particulars are required.
"A bill of particulars is required only where the charges of the indictment are so general
that they do not advise the defendant of the specific acts of which he is accused." United States V.
Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g.,
United States V. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26,
2014) (same); United States V. Mandell, 710 F. Supp. 2d 368, 384 (S.D.N.Y. 2010) (same).
"Acquisition of evidentiary details is not the function of the bill of particulars." United States V.
Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States V. Marcus,
628 F.3d 36, 41 (2d Cir. 2010) (quotations marks and citation omitted).
EFTA00023910

=== Page 2 ===
Nor may a bill of particulars be used as a general investigative tool. "It is not enough that
the information would be useful to the defendant; if the defendant has been given adequate notice
of the charges against him, the government is not required to disclose additional details about its
case." United States V. Payden, 613 F. Supp. 800, 816 (S.D.N.Y. 1985); see also, e.g., United
States V. Sindone, No. 01 Cr. 517 (MBM), 2002 WL 48604, at *1 (S.D.N.Y. Jan. 14, 2002) (a
defendant may not "use a bill of particulars to preview the government's evidence or trial strategy,
or to require the government to specify the minutiae of how it will prove the charges. The stakes
in a criminal case are high, and temptations of perjury, subornation and intimidation are ever
present. Accordingly, the government is not required to turn over information that will permit a
defendant to preview the government's case and tempt him to tailor proof to explain it away, or
see to it that the government's proof is not presented." (citations omitted)); United States V.
Guerrerio, 670 F. Supp. 1215, 1225 (S.D.N.Y. 1987) (A bill of particulars "is not a discovery tool
and is not intended to allow defendants a preview of the evidence or the theory of the government's
case.").
A bill of particulars is unwarranted in this case because the Government has more than
satisfied its obligations to provide the defense with sufficient information to "prepare for trial, to
prevent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted
a second time for the same offense." United States V. Bortnovsky, 820 F.2d 572, 574 (2d Cir.
1987). The Indictment contains a written statement of the essential facts constituting the offenses
charged, and it describes the conduct of the defendant that the Government expects to prove at trial
with respect to three particular victims. The Indictment itself contains a detailed description of the
accounts these victims have provided law enforcement. In addition to the Indictment, which
provides more than sufficient information about the charges against your client, you are also in
possession of, among other things, numerous search warrant affidavits that outline evidence
revealed during the Government's investigation over time (see, e.g., SDNY_GM_00000423-
SDNY_GM_00000524); documentary evidence, including travel records and contemporaneous
journal entries that corroborate the victims' accounts; and the Government's letters concerning
bail and detention. In sum, the Indictment and the materials produced during discovery provide
you with more than ample information concerning the allegations that the Government intends to
prove at trial and the supporting evidence. See, e.g., United States V. Reinhold, 994 F. Supp. 194,
201 (S.D.N.Y. 1998) (denying request for bill of particulars where the "indictment is detailed in
its allegations" and the "defendants have had extensive discovery").
To the extent that your requests seek information regarding potential witnesses and/or co-
conspirators or aiders and abettors (Requests 1-20, 22-26), the Government is not required to
provide such information at this time. See, e.g., United States V. D 'Amico, 734 F. Supp. 2d 321,
335 (S.D.N.Y. 2010) ("A bill of particulars is not a general investigative tool, a discovery device
or a means to compel the government to disclose evidence or witnesses to be offered prior to trial."
(quoting United States V. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States V.
Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as
to identities of unnamed victims of alleged murder conspiracy); United States V. Castro, No. 08
Cr. 268 (NRB), 2008 WL 5062724, at *2 (S.D.N.Y. Nov. 25, 2008) ("An indictment need not
identify all alleged co-conspirators, nor specify the nature, time and place of every overt act the
defendant or others allegedly took in furtherance of a conspiracy, nor must it set forth all the
evidence the government intends to introduce."); United States V. Sindone, 2002 WL 48604, at *1
2
EFTA00023911

=== Page 3 ===
(denying request for bill of particulars that would identify alleged co-conspirators and victims);
United States V. Trippe, 171 F. Supp. 2d 230, 240 (S.D.N.Y. 2001) ("[D]emands for particular
information with respect to where, when, and with whom the Government will charge the
defendant with conspiring are routinely denied."); United States V. Mitlof, 165 F. Supp. 2d 558,
569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the "wheres, whens and with
whoms' that [c]ourts have held to be beyond the scope of a bill of particulars." (collecting cases));
United States V. Fruchter, 104 F. Supp. 2d 289, 313 (S.D.N.Y. 2000) (denying "Defendants"
request for names of all aiders, abettors, unindicted co-conspirators, and confidential informants"
as "nothing more than a request for a witness list"); see also Fed. R. Crim. P. 16. As previously
stated, and as noted in the Government's letter dated October 28, 2020, with regard to your many
requests for information that fall within the scope of the Government's Giglio and Jencks Act
obligations, we intend to produce all such material in advance of trial and remain available to
confer generally regarding a mutual schedule for pretrial and trial-related disclosures, including
witness statements or Giglio material.
You seek numerous, specific details which amount to requests for a detailed preview of the
Government's case and its legal theories (Requests 7, 14, 19, 25, and 29). The Government is not
required to disclose at this juncture the way in which it expects to prove the charges or the precise
manner in which the defendant committed the charged crimes, nor must the Government provide
a preview of the evidence or legal theories it intends to present at trial. See, e.g., United States V.
Dupigny, 18 Cr. 528 (JMF), 2019 WL 2327697, at *2 (S.D.N.Y. May 30, 2019) (denying motion
for bill of particulars and explaining that the defendant "need not be informed of the specific means
of coercion he is alleged to have employed against the still-unidentified victims in the Superseding
Indictment. And between the indictment, applications for search warrants, court filings, and
proffers during bail hearings, the Government has advised Dupigny of the nature and timeframe
of the conspiracy; the number of victims involved in the substantive trafficking offenses, the ages
of several of the victims, and the residence from which he recruited them; and the types of physical
force and coercion he has employed against at least some of them"); United States V. Pierre-Louis,
16 Cr. 541 (CM), 2018 WL 4043140, at *7 (S.D.N.Y. Aug. 9, 2018) ("Defendant's demand that
the Government provide him with the specifics of how it will prove the 'interstate transportation'
element of its case is an improper attempt to limit the Government's proof at trial and is the type
of "when, where, and how' bill of particular requests that are "almost uniformly
denied."
(citation omitted)); United States V. Monzon-Luna, No. 11 Cr. 722 (RRM), 2014 WL 223100, at
*4 (E.D.N.Y. Jan. 21, 2014) (denying request for bill of particulars where defendant was charged
with, among other things, sex trafficking of minors and a Mann Act violation, and stating that the
indictment "explains the essential facts constituting each of the crimes charge[d], the time frame
in which the crime is alleged to have occurred, and the victim involved. This information is
sufficient to apprise defendant of the charges against him."). For example, with respect to Requests
7, 14, 19, and 25, the Government directs your attention to the Indictment, at paragraphs 11(b), 13,
17(b), and 19, which refer to sex acts in violation of New York Penal Law, Section 130.55. With
respect to Request 28, the Government refers you to the Indictment, at paragraph 7, which
describes the conduct of the defendant that the Government expects to prove at trial with respect
to three particular victims. Based on the foregoing, you are not entitled to the particulars sought
through your requests, and in any event, much of what you seek is described in the Indictment and
discovery. If you have authority for your requests, we would be happy to consider it.
3
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=== Page 4 ===
Please let us know if you have any questions or would like to discuss the foregoing.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney for the
Southern District of New York
By:
/
/
Assistant United States Attorneys
4
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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Cc:
)"
Subject: RE:
follow-up request
Date: Thu, 07 May 2020 22:57:05 +0000
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day -whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
EFTA00025329

=== Page 2 ===
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
)
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
EFTA00025330

=== Page 3 ===
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
)
Subject: RE:
follow-up request
EFTA00025331

=== Page 4 ===
Thanks very much, Sigrid. Yes, we received the photographs from
.
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
i
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
i
Subject:
follow-up request
Hi Sigrid,
EFTA00025332

=== Page 5 ===
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00025333


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Subject: FW: Second Circuit Bail Decision
Date: Thu, 01 Aug 2019 15:05:58 +0000
Attachments: boustani.pdf; ATT00001.htm
From:
(USANYS)
Sent: Thursday, August 1, 2019 11:05 AM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Fwd: Second Circuit Bail Decision
Begin forwarded message:
From:
(USANYE) 12"
Date: August 1, 2019 at 11:01:20 AM EDT
To:
(USANYS)"
Subject: Fwd: Second Circuit Bail Decision
FYI
Begin forwarded message:
From:
(USANYE)"
Date: August 1, 2019 at 10:56:49 AM EDT
To: USANYE-Brooklyn_Criminal_Attorneys
Cc:
(USANYE)"
Subject: Second Circuit Bail Decision
The Second Circuit today issued an opinion today that will affect bail motions in white collar
cases and other cases where wealthy defendants seek to be released to home confinement
and monitored by private security companies. Specifically, in United States V. Boustani (copy
attached), the court held that the Bail Reform Act does not permit wealthy defendants to be
released to "self-funded private jails" in circumstances where poorer defendants would be
detained:
"We now expressly hold that the Bail Reform Act does not permit a two-tiered bail
system in which defendants of lesser means are detained pending trial while wealthy
defendants are released to self-funded private jails. It is a fundamental principle of fairness
that the law protects 'the interests of rich and poor criminals in equal scale, and its hand
extends as far to each.' To interpret the Bail Reform Act as requiring district courts to permit
EFTA00024831

=== Page 2 ===
wealthy defendants to employ privately funded armed guards where an otherwise similarly
situated defendant without means would be detained would violate this core principle. Such
a two-tiered system would 'foster inequity and unequal treatment in favor of a very small
cohort of criminal defendants who are extremely wealthy."
Slip op. at 7
The court recognized one potential exception to this principle, i.e., "where the defendant is
deemed to be a flight risk primarily because of his wealth. In other words, a defendant may
be released on such a condition only where, but for his wealth, he would not have been
detained." Id. But it appears that this exception is a narrow one, since the district court in
Boustani cited the defendant's wealth as "one of many factors" but "did not rely primarily on
Boustani's personal wealth in finding that he posed a flight risk." Slip op. at 9. Thus, because
"[a] similarly situated defendant of lesser means surely would be detained pending trial,
Boustani is not permitted to avoid such a result by relying on his own financial resources to
pay for a private jail."
I do not expect that this opinion will be the last word on this issue, but it is now the
governing law in the Second Circuit.
EFTA00024832


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=== Page 1 ===
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 7/7/2020
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
An arraignment, initial conference, and bail hearing in this matter is hereby scheduled to
occur as a remote video/teleconference using an internet platform on July 14, 2020 at 1 p.m. In
advance of the conference, Chambers will email counsel with further information on how to
access the video conference.
To optimize the quality of the video feed, only the Court, the Defendant, defense counsel,
and counsel for the Government will appear by video for the proceeding; all others may access
the audio of the public proceeding by telephone. Due to the limited capacity of the internet
platform system, only one attorney per party may participate by video. Co-counsel, members of
the press, and the public may access the audio feed of the proceeding by calling a dial-in number,
which the Court will provide in advance of the proceeding by subsequent order.
Given the high degree of public interest in this case, a video feed of the remote
proceeding will be available for viewing in the Jury Assembly Room located at the Daniel
Patrick Moynihan Courthouse, 500 Pearl Street, New York, NY. Due to social distancing
requirements, seating will be extremely limited; when capacity is reached no additional persons
will be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who appears
at any S.D.N.Y. courthouse must complete a questionnaire on the date of the proceeding prior to
EFTA00024443

=== Page 2 ===
arriving at the courthouse. All visitors must also have their temperature taken when they arrive
at the courthouse. Please see the instructions, attached. Completing the questionnaire ahead of
time will save time and effort upon entry. Only persons who meet the entry requirements
established by the questionnaire and whose temperatures are below 100.4 degrees will be
allowed to enter the courthouse. Face coverings that cover the nose and mouth must be worn at
all times. Anyone who fails to comply with the COVID-19 protocols that have been adopted by
the Court will be required to leave the courthouse. There are no exceptions.
As discussed in the Court's previous order, defense counsel shall, if possible, discuss the
Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding.
See Dkt. No. 7. If the Defendant consents, and is able to sign the form (either personally or, in
accordance with Standing Order 20-MC-174 of March 27, 2020, by defense counsel), defense
counsel shall file the executed form at least 24 hours prior to the proceeding. In the event the
Defendant consents, but counsel is unable to obtain or affix the Defendant's signature on the
form, the Court will conduct an inquiry at the outset of the proceeding to determine whether it is
appropriate for the Court to add the Defendant's signature to the form.
Pursuant to 18 U.S.C. § 3771(c)(1), the Government must "make their best efforts to see
that crime victims are notified of, and accorded, the rights" provided to them in that section.
This includes "[t]he right to reasonable, accurate, and timely notice of any public court
proceeding
involving the crime or of any release
of the accused" and "[t]he right to be
reasonably heard at any public proceeding in the district court involving release." Id. §
3771(a)(2), (4). The Court will inquire with the Government as to the extent of those efforts. So
that appropriate logistical arrangements can be made, the Government shall inform the Court by
EFTA00024444

=== Page 3 ===
email within 24 hours in advance of the proceeding if any alleged victim wishes to be heard on
the question of detention pending trial.
Finally, the time between the Defendant's arrest and July 6, 2020 is excluded under the
Speedy Trial Act due to the delay involved in transferring the Defendant from another district.
See 18 U.S.C. $ 3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act
from today through July 14, 2020. Due to the logistical issues involved in conducting a remote
proceeding, the Court finds "that the ends of justice served by [this exclusion] outweigh the best
interest of the public and the defendant in a speedy trial." 18 U.S.C. § 3161(h)(7)(A). The
exclusion is also supported by the need for the parties to discuss a potential protective order,
which will facilitate the timely production of discovery in a manner protective of the rights of
third parties. See Dkt. No. 5.
so ORDERED.
Dated: July 7, 2020
New York, New York
Alim D.Nitto
ALISON J. NATHAN
United States District Judge
EFTA00024445

=== Page 4 ===
All members of the public, including attorneys, appearing at a Southern District of New York
courthouse must complete a questionnaire and have their temperature taken before being allowed
entry into that courthouse.
On the day you are due to arrive at the courthouse, click on the following weblink, or scan the
following QR code with a mobile device camera to begin the enrollment process. Follow the
instructions and fill out the questionnaire. If your answers meet the requirements for entry, you
will be sent a QR code to be used at the SDNY entry device at the courthouse entrance.
https://app.certify.me/SDNYPublic
Note: If you do not have a mobile pnone or mobile pnone number, you must complete the
questionnaire and temperature screening at an entry device at the courthouse.
EFTA00024446


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=== Page 1 ===
From:
To
Subject: Fwd: Expert Testimony
Date: Mon, 02 Nov 2020 17:08:52 +0000
2 work for you on Wednesday?
Sent from my iPhone
Begin forwarded message:
From: Dawn Hughes
Date: November 2 2020 at 10:53:58 AMEST
To:
Cc:
Subject: Re: Expert Testimony
Yes. I would be happy to speak with you all. I have some open time on Wednesday after 2:00. Let
me know what works for you.
Best,
Dr. Hughes
DAWN M HUGHES, PHD ABPP
CLINICAL AND FORENSIC PSYCHOLOGIST
On Thu, Oct 29, 2020 at 3:48 PM
wrote:
Dr. Hughes,
Together with colleagues
I'm one of the federal prosecutors handling
the case of United States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2021 in the
Southern District of New York. We would be interested in speaking with you about your availability to
testify as an expert witness at trial. Are you available for a call tomorrow or next week to discuss?
Thanks very much,
EFTA00024754

=== Page 2 ===
EFTA00024755


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=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc: Christian Everdell
"Mark S. Cohen"
<
>,
Subject: Re: Ghislaine Maxwell 02879-509
Date: Thu, 19 Nov 2020 15:36:52 +0000
She is not in the SHU.
>>> BOBBI C STERNHEIM
> 11/19/2020 10:36 AM >>>
Thank you.
Please confirm whether she is in her isolation cell or in the SHU.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Nov 19, 2020, at 10:29 AM,
wrote:
Bobbi-
I received your email after hours yesterday and just haven't had a chance to respond yet.
Your client came in close contact with a staff member who tested positive. Out of an abundance of caution and for the
safety of Ms. Maxwell, staff, visitors and other inmates, MDC Brooklyn has placed Ms Maxwell in quarantine status. She as
you are aware was tested into quarantine and will be tested out in approximately 14 days. Once all the tests are negative
she will be placed out of quarantine. Her legal calls and discovery will continue. She will be unable to have in person legal
visits to protect visitors from potential exposure.
>>> BOBBIC STERNHEIM
11/19/2020 10:25 AM >>>
Good morning-
I am counsel for Ghislaine Maxwell 02879-509.
EFTA00026460

=== Page 2 ===
I have a confirmed legal call scheduled for today (Thursday)
and a confirmed in-person visit scheduled for Saturday
with Ms. Maxwell
I am informed that Ms. Maxwell received a nasal swab test yesterday
and was being placed in the SHU for 14 days.
Please confirm:
-whether she is being quarantined;
-whether she is being confined to the SHU
If so, please explain:
- the reason for the quarantine;
- the duration of the quarantine;
- whether she will be given legal calls;
- whether her legal visits are canceled;
- whether her legal materials and possessions have been transferred with her
and in her possession; and
- whether she is permitted to review electronic discovery.
Your immediate response is requested and appreciated.
I can be reached at
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00026461


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=== Page 1 ===
From:
)"
To: Christian Everdell
, "Mark S. Cohen"
>, Laura Menninger
X
"Jeff
Pagliuca"
>, , "Bobbi Sternheim
(
)"
Cc:
)"
(USANYS)"
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Fri, 09 Oct 2020 00:00:39 +0000
Attachments: 2020-10-08_Letter_to_GM_counsel_re_discovery_&_MDC_conditions.pdf
Counsel,
Attached please find a letter responding to your correspondence of September 21, 2020 and October 1, 2020 regarding
the above-captioned case.
As noted in this letter, today the MDC approved the Government's request to allow an FBI agent bring a secure laptop to
the institution for you to review with your client, so long as no other electronic devices are brought into the room with
the secure laptop. Please let me know what day or days you would like to schedule such a visit for next week, and I will
coordinate with the FBI and the MDC to arrange the visit.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00026812


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=== Page 1 ===
From:
To:
Subject: RE: brief
Date: Sun, 12 Jul 2020 17:41:33 +0000
Attachments: 2020-07-12_GM_detention_reply_brief_(MC).docx
Attached with my proposed edits (mostly nits and the addition of the paragraph I emailed about earlier). Thanks so much
for all your incredible work on this,
From:
Sent: Sunday, July 12, 2020 1:22 PM
To:
Cc
Subject: Re: brief
Will do, and on my list this afternoon to do some other stuff like that that you asked earlier. I'm gonna log on in ten and
read first and then the other stuff and then circle up.
Sent from my iPhone
On Jul 12, 2020, at 13:17,
wrote:
could you please save the slip-and-fall deposition here:
Thanks.
From:
Sent: Sunday, July 12, 2020 1:09 PM
To:
Cc:
Subject: Re: brief
l'll call
now and then take a look right after.
Sent from my iPhone
On Jul 12, 2020, at 13:02
wrote:
Attached.
From:
Sent: Sunday, July 12, 2020 12:39 PM
To:
Cc:
Subject: Re: brief
yup
EFTA00024492

=== Page 2 ===
Sent from my iPhone
On Jul 12, 2020, at 12:38,
wrote:
Hi team - I'm going to send you the draft incorporating
is changes in about half an hour. Are you able to give it a
quick read to make sure you're comfortable with some of the alterations/additions? Thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
2020-07-12 GM detention reply brief.docx>
EFTA00024493


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
Subject: Accepted: Epstein Call
Date: Thu, 21 May 2020 13:57:34 +0000
Importance: Normal
Attachments: unnamed
EFTA00026538


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Thu, 27 Aug 2020 16:20:39 +0000
Hi
So far, actually seems to be functioning. Sorry for the false alarm, but perhaps she just figured out how to open the files she
was previously having difficulty with.
If I receive any follow up about additional issues, I will let you know.
Appreciate your responsiveness and willingness to help!
8/26/2020 3:41 PM >>>
There are many different types of files on the drive; excel, pdf, tif, video, audio, etc. Consequently, it will be difficult to
diagnose the issue(s) without knowing the specific files/folders that are problematic. If you would send over the particulars
we will work to provide a fix.
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, August 26, 2020 3:23 PM
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Hi
Thanks very much for reaching out. I'm adding
who may be able to answer your question.
If there are particular files that Maxwell is having difficulty opening, please let us know, and we can try to figure out how to
address the issue.
EFTA00023962

=== Page 2 ===
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, August 26, 2020 2:45 PM
Subject: Re: delivery of hard drive to MDC for discovery production to inmate
Good afternoon,
Maxwell was provided this drive on Tuesday. Staff have reported to me that she has reported that certain files do not work.
Can you advise what types of files (i.e., video/excel/etc.) are on the drive and what players or applications may be necessary
to view them? I'm trying to figure out what reasons may be for issues with the material on the drive.
Thank you,
8/21/2020 9:01 PM>>>
We just sent another drive via FedEx. This drive contains all of the discovery in the case to date. The password for the drive
is
(which we also sent in a separate letter).
Yes, these productions contain audio as well as video.
Let me know if you have any other questions. Have a good weekend.
Best,
Sent from my iPhone
On Aug 14, 2020, at 7:34 AM,
wrote:
Thank you for letting me know! Are you aware of whether this production contains any audio discovery?
Thank you,
EFTA00023963

=== Page 3 ===
8/13/2020 5:05 PM >>>
I just sent the next round of discovery via FedEx. The password for this drive is USAO_sdny2020! We also sent a letter
with the password in a separate envelope.
Please let us know when it arrives.
Thank you,
Madison
From:
Sent: Monday, August 10, 2020 6:03 PM
Subject: Re: delivery of hard drive to MDC for discovery production to inmate
That should be enough to track it down, thank you! If I have any issues, I'll let you know.
Best,
8/10/2020 5:59 PM >>>
I sent this via FedEx. When I enter the tracking number it says:
Delivered
Friday 8/07/2020 at 7:16 am
Let us know if you have any other questions.
Thanks!
Sent from my iPhone
On Aug 10, 2020, at 5:48 PM,
wrote:
Good evening
Just confirming - did you use FedEx, USPS, or some other carrier to send the discovery here? I have not received it yet,
but it could just be that staff did not notify me a package arrived. Depending on the carrier, it could be in the warehouse
or mailroom, so I just want to verify so I can find it expeditiously.
Thanks!
8/5/2020 7:13 PM >>>
That's extremely helpful, thanks so much. We'll plan to put the drive in the mail tomorrow, and of course please let us
know if any issues arise.
thanks again,
From:
Sent: Wednesday, August 05. 2020 19:05
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password
protected so long as you include a cover letter that contains the password for her.
Hope this helps,
EFTA00023964

=== Page 4 ===
8/5/2020 4:34 PM>>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could
you please let us know what the current protocol is for that? Also, it's our understanding that hard drives with
discovery materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
if it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00023965


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=== Page 1 ===
Event: Accepted: Update Conference Call - Epstein
Start Date: 2019-08-13 13:30:00 +0000
End Date: 2019-08-13 14:00:00 +0000
Location: Dial-in below
Class: X-PERSONAL
Comment:
Date Created: 2019-08-13 00:47:52 +0000
Date Modified: 2019-08-13 00:47:52 +0000
Priority: 5
DTSTAMP: 2019-08-13 00:32:16 +0000
Attendee:
(USANYS)
EFTA00024398


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: Maxwell disclosure question
Date: Mon, 14 Sep 2020 15:25:40 +0000
Attachments: 2020-01-08,
interview_302.pdf; 2020-01-
08.
,
Interview_Notes.pdf;_2020-02-05,
Interview_302.pdf;
2020-02-05.
_interview_notes.pdf
Chiefs,
We'd like to set up a call to discuss the attached statement by
mother during our interviews with her. Is
there a good time to talk?
Thanks,
EFTA00024728


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From:
)"
To:
(USANYS)"
Subject: Automatic reply: WSJ News Alert: Jeffrey Epstein Found Dead in Jail, Officials Say
Date: Sat, 10 Aug 2019 14:05:39 +0000
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses may be
delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00024349


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=== Page 1 ===
From:
To:
(USANYS);
Subject:
2021.03.03 call with Dr. Rocchio
Date:
Wednesday, March 3, 2021 1:24:41 PM
AUSAs
on call with Dr. Rocchio
Dr. Rocchio has been working with survivors of sexual trauma since graduate training on,
including while at Yale in post-doctoral training. Primary client population in post-doctoral
training were clients receiving therapy designed to treat primarily women who were suicidal,
the vast majority of whom had experienced some sort of trauma and abuse. Then when in
private practice, since 1998, trauma has been Dr. Rocchio's area of expertise and specialty. So
the majority of clients she has worked with have experienced some form of trauma, including
a lot of childhood sexual trauma. Dr. Rocchio has also conducted assessments for courts that
involved assessing juveniles with significant mental health difficulties, the majority of whom
had experienced some form of sexual trauma. She has been involved in assessment and
treatment of sexual trauma throughout entire career.
Beginning of her career, as high as 80% of clients were victims of child sexual abuse,
that percentage has varied over the years from a minimum of a third to as much as
80% of her clients, currently approximately 50% of her clients
Dr. Rocchio is currently the president-elect of APA trauma committee (on CV) and
fellow of that organization
Has treated and evaluated hundreds upon hundreds victims of trauma, been working
for 25 years, and takes at least 20 clients (sometimes more) per year
Has sought specialized training involving sexual trauma:
Took graduate school courses on violence and women
Have taken additional trainings regarding trauma, including numerous continuing
education programs as both a student and a teacher regarding treatment of trauma in
a clinical setting
Training include assessment and treatment of trauma and childhood sexual abuse, as
well as specific to forensic assessment of trauma in criminal and civil settings
Has been involved in multiple different types of civil and criminal cases involving trauma
victims
3502-003
Page 1 of 1
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject:
Date: Wed, 08 Jan 2020 17:44:35 +0000
Attachments: 2020.01.08_letter_to_KMK_re_MCC_tape.docx
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
Tel:
EFTA00026544


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=== Page 1 ===
From:
To:
Subject: review protocol
Date: Mon, 22 Feb 2021 20:41:35 +0000
Attachments: 2020.10.19_Epstein_devices_responsiveness_review_protocol_-_image_&_video_files.docx
Assistant United States Attorney
Southern District of New York
EFTA00026595


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=== Page 1 ===
From:
)"
To:
)"
"
)"
Subject: FW:
)
- Epstein
Date: Tue, 09 Jul 2019 20:52:09 +0000
Importance: Normal
I'm free whenever works for you guys-are either of you free to call sooner?
From: Joe Nascimento
Sent: Tuesday, July 9, 2019 4:43 PM
To:
Cc:
>;
Subject: Re:
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
wrote:
Hi
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00026653

=== Page 2 ===
From:
)"
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
Cc:
)"
i
)"
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on Tuesday - you can reach us at
or we can also call you then if that's easier, whatever you prefer.
thanks,
From: Joe Nascimento
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
>;
Subject: Re:
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may
be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before
you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check
in tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being
in touch.
EFTA00026654

=== Page 3 ===
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
Sent: Saturday, July 06, 2019 22:55
To:
Subject:
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
) - Epstein
My former partner, Alan Ross, represented
,
prior to his passing in
2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am
getting up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00026655


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Sun, 10 Oct 2021 23:17:45 +0000
Chiefs, FYI.
From: BOBBI c STERNHEIM
Sent: Sunday, October 10, 2021 7:03 PM
To:
(BOP)
Cc:
(BOP)
>; Christian Everdell
is
(USANYS)
Subject: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Good evening-
You failed to provide any update concerning the whereabouts of Ms. Maxwell's legal mail that I had placed in the legal
mailbox on 10/2.
However, on Friday afternoon, I was informed by Ms. Maxwell and Unit Manager
that the envelope had
been located and affixed to it
was a bar-code type sticker, not generated by the MDC, but of the type issued by the U.S. Post Office.
I had placed the envelope in the legal mailbox. It did not have postage. If, for some questionable reason, it had been
handled by the U.S. Postal Service
(which is highly unlikely and, if so, deliberately caused by the MDC), the Post Office would have returned it to my office
address (at the return address on the envelope),
not deliver it to the MDC without postage.
This suggests some type of foul play on the part of the MDC, or at least some type of cover-up.
I am informed that the Warden is aware of this. Today, I received the envelope from Unit Manager
Today, Christian Everdell, Esq. and I had a scheduled legal visit with Ms. Maxwell.
Rather than permitting us to use a somewhat larger room, we were required to use a room for two.
This completely defeated the purpose of COVID protective measures. The plastic partition did not shield
Mr. Everdell and there was little or no table surface for him to use. The room was unnecessarily cramped
when a larger room was available. My request to use a larger room was denied. The officer claimed the team could not
position the camera
to focus on the larger room. This response was bogus. I requested to see the Warden, but that request was never
honored.
Further, defense counsel at large have heard about the current electricity issues affecting water, toilet flushing, and meals.
Ms. Maxwell received a bologna sandwich despite being on no-flesh (vegetarian) diet.
This is yet another blunder on the part of the MDC which needs to be immediately corrected.
I will not waste my energy requesting a response because even if forthcoming it will likely be insufficient.
These matters will be brought to the Court's attention, so you can start preparing excuses for consideration by Judge
Nathan.
Enjoy your holiday.
Bobbi
EFTA00025278

=== Page 2 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Oct 7, 2021, at 7:45 AM, BOBBI C STERNHEIM
wrote:
Good morning-
If by 9:30 this morning (10/7) Ms. Maxwell does not receive the legal mail deposited in the MDC legal mailbox on
Saturday (10/2), an order to show cause will be filed with the Court.
I urge you to respond and comply immediately.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Oct 6, 2021, at 7:00 PM, BOBBI C STERNHEIM
wrote:
Good afternoon-
Ms. Maxwell still has not received the legal mail (a properly addressed manila envelope)
that I deposited in the East Building legal mailbox on Saturday 10/2 shortly after 3 pm
while I was escorted to the lobby by a male guard.
Please contact me immediately.
EFTA00025279

=== Page 3 ===
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may
be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On Oct 6, 2021, at 4:53 AM,
wrote:
I will follow up with the appropriate departments.
BOBBI C STERNHEIM
10/5/2021 7:12 PM
Good evening-
As of this writing, Ms. Maxwell has not received legal mail which I
personally placed in the
East Building legal mailbox on Saturday, October 2. On that same day,
in that same mailbox,
I deposited legal mail for a client housed in the west building. That
client confirmed that he received his legal mail.
Ms. Maxwell has not.
Please explain why delivery of Ms. Maxwell's mail has been delayed.
Time is of the essence. Her trial begins on November 29th.
Every delay caused by the MDC interferes with her ability to prepare
for trial.
Your prompt response is requested.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00025280

=== Page 4 ===
Main:
Cell:
Fax:
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.
EFTA00025281


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=== Page 1 ===
From:
To:
Subject: Fwd: gloria allred purchases prince andrew 'wanted' poster
Date: Fri, 21 Feb 2020 14:04:38 +0000
Inline-Images: image001.jpg
Sent from my iPhone
Begin forwarded message:
From: "Katersky, Aaron" <Aaron.Katersky@abc.com>
Date: February 21, 2020 at 9:00:21 AM EST
To:
Subject: FW: gloria allred purchases prince andrew 'wanted' poster
Attorney Gloria Allred said she placed an ad on a school bus that circled Buckingham Palace this morning, calling for him
to talk to the FBI about the Jeffrey Epstein case.
The bus carried a large picture of the prince accompanied by the message -- "If you see this man please ask him to call
the FBI to answer their questions."
Allred just discussed her stunt outside criminal court in Lower Manhattan, where she is attending the Harvey Weinstein
trial.
Allred who represents some of Epstein's victims.
Allred displayed a photo of the bus on her computer and a photo from the Press Association is below
you see this nan please ask him to call
the
FBI
to
answer
their
questions
324-3000
gloriaalired.com
gloriaalired.com
The message on the bus was from US lawyer Gloria Allred. Photograph: Stefan Rousseau/PA
EFTA00026869


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: SDNY investigation
Date: Wed, 10 Jul 2019 18:38:50 +0000
Importance: Normal
Mr. Kaiser,
Thank you again for speaking with us today in connection with our investigation of Jeffrey Epstein. As we mentioned on
the phone, we are interested in speaking with your client, and we appreciate her willingness to meet with us. So you have
the contact info for all of our team, we can all be reached anytime at the emails here or via phone at:
As we spoke about a few minutes ago, we would be happy to meet with you and your client at our office this Friday, July
12, at 2:00 p.m. We're located at 1 St. Andrew's Plaza, in downtown Manhattan - the office is right by the Brooklyn
Bridge 4/5/6 and J/Z subway stop, or with a few blocks of various Chambers Street stops on other lines. If you've ever
been to 1 Police Plaza, it's right next door, slightly behind a large red outdoor sculpture. And if you have any issues finding
the building, you can call me directly
When you get to the building, just
let security know you're here to see me and come down and bring you in.
Please let me know if you have any questions at all, or if it would be useful to talk further before Friday, and thank you
again.
Assistant U.S. Attorney
District of New York
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=== Page 1 ===
From: Christian Everdell
To:
Subject: [EXTERNAL] RE: Draft joint proposed request to charge
Date: Mon, 25 Oct 2021 22:58:41 +0000
Attachments: 2021.10.25_Letter_to_Judge_Nathan_re_Extension_of_TimeDOCX
Attached is the letter we intend to file with the Court regarding the extension to file the jury charge. It should reflect
everything we discussed on our call earlier today.
Please let me know if you have any issues with it as soon as you can. I'd like to file it in the next hour or so.
Thanks,
Chris
From:
Sent: Monday, October 25, 2021 2:29 PM
To: Christian Everdell
>; BOBBI C STERNHEIM
>; Jeff Pagliuca
>; Laura Menninger
Cc:
Subject: RE: Draft joint proposed request to charge
Hi Chris,
That works. I'm around this afternoon - give me a call at
whenever you have a minute.
Thanks,
From: Christian Everdell
Sent: Monday, October 25, 2021 1:56 PM
To:
>; BOBBI C STERNHEIM
>; Jeff Pagliuca
>; Laura Menninger
Cc:
Subject: [EXTERNAL] RE: Draft joint proposed request to charge
I think I have a way to come to an agreement on this. I know today is extremely busy for all of us, but can you and I have a
5 min. call to discuss? I don't think everyone from SDNY needs to be on this call, but I leave that to you.
Thanks,
Chris
EFTA00025037

=== Page 2 ===
From:
Sent: Sunday, October 24, 2021 3:10 PM
To: Christian Everdell
>; BOBBI C STERNHEIM
>; Jeff Pagliuca
>; Laura Menninger
Cc:
Subject: RE: Draft joint proposed request to charge
Hi Chris,
I think the answer is yes, but just to make sure: we'd file the Government's proposal on Wednesday, you'd file whatever
redline you like on November 3. It also occurs to us that, since your redline will presumably contain new
proposals/objections to ours and would not include our views, we'd want to file a short reply on November 5 or 8.
We'd consent to that option and, if you like, would join your motion for that schedule.
Thanks,
From: Christian Everdell
Sent: Sunday, October 24, 2021 12:35 PM
To:
>; BOBBI C STERNHEIM
>; Jeff Pagliuca
>; Laura Menninger
Cc:
is
(USANYS)
Subject: [EXTERNAL] RE: Draft joint proposed request to charge
Hi
I just want to clarify the redline option. If we did the redline option, would you file the government's RTC (without
defense comment) on Oct. 27 and then we would file the joint RTC (i.e., our redline of your RTCs) on Nov. 3? And you
would consent to that option?
Thanks,
Chris
From:
Sent: Friday, October 22, 2021 2:30 PM
To: Christian Everdell
>; BOBBI C STERNHEIM
>; Jeff Pagliuca
>; Laura Menninger
Cc:
Subject: RE: Draft joint proposed request to charge
Hi Chris,
We had another idea that might facilitate things. We know Judge Nathan asked for a joint RTC, but what about asking
Judge Nathan to let us file separate ones? We would also be comfortable setting a deadline for the defense RTC (or a
defense redline of ours) on November 3.
If you were to make a request to file separate RTCs, with your deadline on November 3, we would join that request.
Thanks,
EFTA00025038

=== Page 3 ===
From: Christian Everdell
Sent: Wednesday, October 20, 2021 4:07 PM
To:
>; BOBBI C STERNHEIM
>; Jeff Pagliuca
>; Laura Menninger
Cc:
Subject: [EXTERNAL] RE: Draft joint proposed request to charge
Hi
Given all of the other things we have going on this week, the defense would like a little more time to submit the joint
requests to charge. We plan to ask the Court for an extension until Monday, Nov. 1. Does the government consent to that
request?
Thanks,
Chris
From:
Sent: Wednesday, October 20, 2021 12:30 PM
To: Christian Everdell
>; BOBBI C STERNHEIM
>; ; Jeff Pagliuca
>; Laura Menninger
Cc:
Subject: Draft joint proposed request to charge
Counsel,
Attached please find a draft joint proposed request to charge. Since this is due to the Court on Wednesday, October 27,
please send us your comments by Sunday, October 24. Please also send us your comments, including any additional
proposed jury instructions, as a redline to this document.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00025039


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=== Page 1 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On May 10, 2021, at 6:00 PM,
wrote:
Hi Bobbi,
Thanks for following up. It seems that the parties agree about a November 2021 trial date but disagree about the week,
and we plan to file a letter this evening to that effect. We are not able to agree to a November 8th trial date, given the
need for continuity of counsel and the potential unavailability of a trial witness, but thank you for conferring with us
about this.
From: BOBBI C STERNHEIM
Sent: Monday, May 10, 2021 5:34 PM
Cc: Christian Everdell
Laura Menninger
; Jeff Pagliuca
Subject: US V. Maxwell -Trial Start Date
Good afternoon-
Following up on the status of our conferral emails as our joint letter (re: trial start date) is due today.
Thanks-
Bobbi
EFTA00024912

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BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**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.
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This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
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On May 9, 2021, at 12:14 PM, BOBBI C STERNHEIM
wrote:
Good afternoon-
In our 4/22 letter, we provided specific details concerning cases and trial dates
to justify our request for a continuance to 11/8.
Beyond a vague statement regarding consideration of availability of witnesses and counsel,
you have provided no specific details why the government cannot proceed to trial on 11/8.
Starting the trial on 11/29 - besides disrupting Thanksgiving holiday plans - will push the trial
to the end of the year and possibly into the new year, interfering with Christmas and
New Year's plans, as COVID did last year. This will cast the defense and defense case
in a negative light as jurors impatiently wait for the trial to conclude before Christmas, which it won't.
Our previous email explained our reasons for firmly pressing the 11/8 trial date,
but as an accommodation, we would consider starting on 11/15, but no later.
For now, we will not agree to exclusion of speedy trial time beyond 11/8.
These scheduling conflicts can be easily eliminated by consenting to bail for Ms. Maxwell.
It is unclear why the scheduling order, which contemplated a continuance, should be altered.
As previously discussed and raised with the Court, we need to review of 3500 material
and exhibits before determining the need to call any experts.
Enjoy the day.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On May 7, 2021, at 9:30 PM
wrote:
Bobbi,
Thanks very much for letting us know your availability. Regarding the trial date, after considering the availability of
witnesses and counsel, we plan to propose a trial date of November 29, 2021. Could you please let us know your
position regarding that date, so that we can include it in our letter to the Court? In addition, please let us know
whether you consent to an exclusion of time under the Speedy Trial Act between now and the new trial date the
Court selects.
With respect to other scheduling matters, we intend to propose that the Court set a deadline of three months before
trial for the Government to disclose the identities of victims referenced in the indictment; this is an earlier proposal
than the timeframe we had originally proposed for the July trial date. We also intend to propose that the deadline
for defense expert disclosures be set for two months before trial, given the substantial length of the adjournment.
Please let us know your position regarding those proposed dates and we'll include it in our letter.
Thanks very much, and hope everyone has a nice weekend--
From: BOBBI C STERNHEIM
Sent: Friday, May 7, 2021 5:26 PM
Christian Everdell
Laura
Menninger
; Jeff Pagliuca
Subject: Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
We are available to begin November 8th and to conclude by the end of the year.
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Laura has a civil trial scheduled for December 13th, but will try to move it.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On May 7, 2021, at 5:16 PM
wrote:
Bobbi,
We understand that you're requesting a November 8th date, and that you prefer that date. Separate from your
preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please
let us know your availability and we will note that accordingly in our submission to the Court?
From: BOBBI c STERNHEIM
Sent: Friday, May 7, 2021 4:00 PM
Cc: Christian Everdell <
; Laura Menninger
Jeff Pagliuca
Subject: Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Good afternoon-
For the reasons stated in our letter-motion of 4/22 (Dkt. 246),
our earliest and preferred date in the fall is 11/8.
In light of Ms. Maxwell's extended period of detention
and its deleterious effect on her health and well-being,
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we cannot agree to a date far beyond 11/8.
However, should you agree to her release pending trial,
we would have greater date flexibility.
Enjoy the weekend.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On May 7, 2021, at 1:13 PM,
wrote:
Hi Bobbi,
Thanks for your response. Your April 22, 2021 letter does not address the defense's availability for trial dates after
November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of
2021 in order to provide the Court with comprehensive information. We're still in the process of conferring with
witnesses regarding their availability, so we're gathering a variety of data points. Please let us know your
availability and we can put together a proposal.
Thanks,
From: BOBBI c STERNHEIM
Sent: Thursday, May 6, 2021 11:58 PM
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Cc: Christian Everdell
; Laura Menninger
Jeff
Pagliuca
Subject: Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Good evening-
Our 4/22 letter detailed our position. Please let us know your availability for 11/8.
Thank you-
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.
On May 6, 2021, at 7:15 PM
wrote:
Counsel,
We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your
preferences and availability for trial dates from September 2021 through the end of the year. If you could please
provide details for any conflicts, that would be helpful.
Thank you,
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