# docs_fts_content

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=== Page 1 ===
From:
Cc:
Subject: RE: Epstein FOIAs
Date: Wed, 11 Mar 2020 13:38:05 +0000
Attachments: 2019.07.02_Indictment_Jeffrey_Epstein.pdf
Hi
Not a problem. I've attached the indictment. The other filings are on docket 19 Cr. 490 (RMB)- - please let me know if
you'd like me to download anything else. Here are the materials on our website:
https://www.justice.gov/usao-sdny/pr/jeffrey-epstein-charged-manhattan-federal-court-sex-trafficking-ninors
https://www.justice.gov/usao-sdny/programs/victim-witness-services/united-states-v-jeffrey-epstein-19-cr-490-rmb
https://www.justice.gov/usao-sdny/pr/statement-manhattan-us-attorney-death-defendant-jeffrey-epstein
As for other items in our possession that are public, we have both a selection of filings from civil cases that we pulled from
public dockets (though I would not necessarily want to reveal which civil suits we tracked), as well as a copy of the FOIA
production that FBI Palm Beach produced regarding the initial investigation.
Thanks,
From:
Sent: Tuesday, March 10, 2020 6:23 PM
To:
Subject: Epstein FOIAs
further to the little meeting we had a couple weeks ago, could you kindly pull together the Epstein press
releases and charges and anything else we made public? (I don't think you need to download everything from the
docket, tho.)
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00009808


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=== Page 1 ===
From:
"
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
Subject: RE:
Date: Mon, 19 Nov 2007 16:40:02 +0000
Importance: Normal
No, I think he is pleading on December 16th, and we should definitely try to keep that date on track.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
Original Message
From:
(USAFLS)
Sent: Monday, November 19, 2007 11:38 AM
To:
(USAFLS);
(USAFLS)
Subject: FW:
Clearly Epstein believes that January 4th not December 16th is when he'll plead guilty and be sentenced. Judging from
email, it seems that January 4th is the date. Hopefully, I'll hear from Judge Davis today or tomorrow. Thanks,
Original Message
From: Jay Lefkowitz [mailto:
Sent: Friday, November 16, 2007 2:00 PM
To:
(USAFLS)
Subject:
- Beyond my letter the other day, and your email
to me from a few weeks ago, is there anything else you
need from me regarding the plea and sentencing dates.
As we discussed, and as we have confirmed, the Court
has told us she will handle both at the same time (plea
before sentencing, obviously), and to the agreed-upon
counts, on Jan 4. I trust I have cleared up any
confusion regarding Jan 7.
Thx. Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
EFTA00013704

=== Page 2 ===
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013705


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=== Page 1 ===
From:
)"
To: "Singer, Linda"
Subject: Accepted: Call w/ DOJ re. Epstein SDNY Investigation
Date: Mon, 05 Oct 2020 12:20:14 +0000
Importance: Normal
Attachments: unnamed
EFTA00010328


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From: "
(USAFLS)"
To: "
(USAFLS)"
Subject: Re: Agreement
Date: Thu, 14 Aug 2008 13:59:10 +0000
Importance: Normal
Ok
Original Message
From:
(USAFLS)
To:
(USAFLS)
Sent: Thu Aug 14 09:58:36 2008
Subject: Agreement
Hi
- Just talked to
and he disagrees with our strategy. He is going to call and explain his reasoning. Here are the three
documents.
<Epstein Agrmt001.pdf>>
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014121


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From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)
[Contractor]"
Cc:
)"
Subject: RE: US V. Maxwell - missing testifying witness materials
Date: Mon, 08 Nov 2021 17:02:36 +0000
Attachments: 3521-003.pdf; 3521-004.pdf
the two re-stamped versions are attached. I'll call
chambers and set a time for me to bring over the thumb
drive containing the supplemental 3500 production (with the correct 3521-003 and 3521-004 included). Thanks!
From:
(USANYS) [Contractor]
Sent: Monday, November 8, 2021 9:48 AM
To:
(USANYS)
(USANYS) [Contractor]
Cc:
Subject: RE: US V. Maxwell - missing testifying witness materials
Thanks so much for flagging,
I just re-stamped the materials as 3521-003 and 3521-004, saved here. I've loaded the
two files to the thumb drive for
that contains the supplemental 3500 production and swapped out the incorrect
versions. If that sounds good to go, I can bring it over to chambers later this morning.
Since I'm joining this production a bit late, do these two re-stamped files need to be sent out anywhere else? Thanks!
From:
(USANYS)
Sent: Saturday, November 6, 2021 5:59 PM
To:
(USANYS) [Contractor]
is
USANYS) [Contractor]
Cc:
Subject: FW: US V. Maxwell - missing testifying witness materials
The index listed this correctly as 3521-003 and 3521-004, but we produced as 3521-004 and 3521-005 (I think). When you
have a chance, can you please confirm? If so, I think let's reproduce as 3521-003 an 3521-004, but let me know if you
think that will be more confusing/make more work.
Thanks,
From: Laura Menninger
Sent: Saturday, November 6, 2021 5:53 PM
To:
is
(USANYS)
i
is
Cc: Jeff Pagliuca
Subject: [EXTERNAL] US V. Maxwell - missing testifying witness materials
Counsel -
We were not provided
3521-003 material.
EFTA00009981

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Can you please confirm whether that was intentional, and if not, provide it?
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00009982


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=== Page 1 ===
From: FAXmaker
To: 15618208777
Page: 2/2
Date: 7/21/2008 6:38:17 PM
LEWIS TEIN PL
ATTORNEYS AT LAW
July 21, 2008
Copy via facsimile
Esq.
Office of the United States Attorney
500 S. Australian Avenue
West Palm Beach, Florida 33401
RE: Jeffrey Epstein
Dear
:
Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein "intends to fully
abide by the Non-Prosecution Agreement." The answer is yes.
We confirm as you state in your letter that the Agreement requires that "the federal Grand Jury
investigation will remain suspended, and all pending federal Grand Jury subpoenas will be held
in abeyance unless and until [Mr.] Epstein] violates any term of [the Non-Prosecution
Agreement]." We also confirm that under the Agreement, "prosecution in this District for these
offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein
abides by the
conditions and the requirements of th[e] Agreement."
As you know, there is no provision in the Agreement referring in any way to Section 3509(k).
By that statute, Congress imposed a mandatory obligation on federal district courts to stay
certain civil cases. Its operation is not subject to the control or discretion of any party. Whether
Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law
for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise
the Court of its statutory mandate under Section 3509(k).
Finally, thank you for notifying me that our motion to quash technically remains outstanding.
We had previously notified the Court that the parties did not wish to argue the issue. I agree that
the Agreement requires its withdrawal and we will file a formal notice withdrawing it this week.
Please do not hesitate to call me if you wish further clarification of our position or to discuss this
matter in any way. Until then, I remain,
Very truly yours,
United
Michael R. Tein
CC:
Jack Goldberger, Esq.
Roy Black, Esq.
Alex Acosta, Esq.
3059 GRAND AVENUE
SUITE 340
COCONUT GROVE, FLORIDA 33133
TELEPHONE (305) 442-1101
FACSIMILE (305) 442.6744
WWW.LEWISTEIN.COM
This fax was sent with GFI FAXmaker fax server. For more information, visit: http://www.gfi.com
EFTA00014005

=== Page 2 ===
From: FAXmaker
To: 15618208777
Page: 1/2
Date: 7/21/2008 6:38:17 PM
Lewis Tein
PL
ATTORNEYS AT LAW
FACSIMILE TRANSMISSION
RECIPIENT:
, Esq.
RECIPIENT'S FAX NUMBER:
SENDER: Michael R. Tein, Esq.
DATE:
July 21, 2008
PAGES (including cover sheet): 2
COMMENTS:
IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION.
DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED IF YOU HAVE RECEIVED THIS FACSIMILE IN
ERROR, PLEASE NOTIFY US BY TELEPHONE AND RETURN THE ORIGINAL BY MAIL AT THE BELOW ADDRESS. THANK YOU.
LEWIS TEIN, P.L. . 3059 GRAND AVENUE SUITE 340 . COCONUT GROVE, FLORIDA 33133
TELEPHONE (305) 442-1101 - FACSIMILE (305) 442-6744 . WWW.LEWISTEIN.COM
This fax was sent with GFI FAXmaker fax server. For more information, visit http://www.gfi.com
EFTA00014006


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Follow up
Date: Fri, 21 Mar 2008 17:58:21 +0000
Importance: Normal
I will need to look into that, but I do know that there is a 3-year statute of limitations on the state prostitution
charges. That limitations period has already run for several of our victims (we have victims going back to
2001). The girls who are charged in the state indictment saw him in February and September 2005.
I will get the other info to you asap. Give me about 30 minutes.
From:
Sent: Friday, March 21, 2008 11:51 AM
To:
Cc:
Subject: RE: Follow up
One more question - do you know when double jeopardy attaches under Florida law? More specifically, if the
state charges were dropped now, could they be dropped without prejudice?
From:
Sent: Thursday. March 20 2008 4:39 PM
To:
Cc:
Subject: RE: Follow up
Hi
The state indictment is related to two girls. One of those girls is included in the federal
indictment, the other is not. The state indictment charges solicitation of adult prostitution, it does not charge any
child exploitation offense, despite the fact that, under Florida law, neither lack of knowledge of age nor
affirmative misrepresentation of age by the victim is a defense.
The victim from the state case who is referenced in the federal indictment told Epstein her true age and
he engaged in full sexual intercourse with her a few days shy of her 18th birthday. For that birthday, he gave her
a series of gifts, including lingerie. The other 18 girls named in the current indictment are not part of the state
indictment.
The state case currently has a trial date set for July. Before we got involved, the police were told that
Epstein was going to plead to a misdemeanor and get no jail time. (That is one of the reasons why they asked
the FBI to step in.) Since the federal investigation began, Epstein's counsel have continued the case repeatedly
EFTA00013778

=== Page 2 ===
on the basis that they cannot resolve that case until the federal case is resolved. As part of the non-prosecution
agreement that the Office put together with Epstein, the federal case was supposed to be resolved if Epstein
agreed to three main terms: (1) he had to plead to a state offense for which sex offender registration was
required, specifically, the procurement of minors to engage in prostitution; (2) he had to agree to an 18-month
term of incarceration; and (3) he had to agree to pay restitution and damages to the victims. After the agreement
was signed, he then tried to escape all three requirements.
He objected to pleading to the state charge, claiming that the facts did not apply, and asked to plead to a
non-registrable offense instead. When we responded that there were four other registrable offenses where the
facts certainly fit, those were rejected because (1) they required registration and (2) the state sentencing
guidelines for those offenses were too high.
He tried to arrange to get out on work release, which would allow him to "work" anywhere he liked
during the day and sleep in a halfway house, rather than a jail, at night. When he learned that sex offenders
weren't allowed to be a part of the work release program, he started complaining about the jail time. He now
wants to get a "suspended sentence" and/or home confinement, instead.
He complained that he should be able to fully litigate the issues of liability and damages with regard to
the third term of the agreement, despite his agreement directly to the contrary.
With respect to the current status of the state case, other than the new trial date, all that I know is that
Epstein is now subpoenaing victims for depositions who are not included in the state indictment. (Under Florida
law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems to be trying to
use that process to get information about the federal investigation. I do not know whether Epstein's
misdemeanor deal is back on the table because the defense demanded that we have no contact with the State
Attorney's Office, so I haven't spoken with the ASA in over 6 months.
I wish I had more information to give you. If you would like me to reach out to either the local detective
on the state case or the Assistant State Attorney, please let me know. Or, if you would like their contact info, I
can forward that to you, too.
Thank you. I will be back in the office tomorrow and you can call me there with any other questions.
From:
Sent: Thursday, March 20, 2008 11:49 AM
To:
Cc:
Subject: RE: Follow up
Two quick questions: Could you clarify whether any of the victims that are included in the state indictment
would also be included in any federal indictment? If you know, what is the status of the state case?
Thanks,
EFTA00013779

=== Page 3 ===
From:
Sent: Wednesday. March 19. 2008 7:17 PM
To:
Cc:
Subject: RE: Follow up
I'm running out the door, but I wanted to get a response off. Sorry for not updating you sooner. The meeting went well -
enough. They wanted to "complete the record" with some written material, which we expect to have by Monday. We're
putting together our response to their arguments and we should be ready to issue it as soon as we get and digest their final
submissions. Assuming we get the submissions by Monday, I expect to have our position to you by the middle of next
week.
So far we've not had any questions we couldn't answer with the materials at hand, but we'll reach out to you promptly if we
need to.
Thanks,
From:
Sent: Wednesdav. March 19, 2008 6:30 PM
To:
Subject: Follow up
Hi
- Sorry to bother you. I know you had mentioned that you might have some questions for me after
your meeting. I am going to be out most of the day tomorrow and then back on Friday and then I will be out for
a week, so I wanted to get stuff to you before I leave. Do you need anything from me or the investigators?
Thanks.
EFTA00013780


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From:
(USANYS)"
To:
)"
)"
)"
Subject: RE: focus group exercise
Date: Mon, 27 Sep 2021 18:43:49 +0000
Attachments: Maxwell_Mock_Opening_v2.docx
Here is the mock opening, thanks.
From:
)
Sent: Monday, September 27, 2021 2:13 PM
To:
is
Cc:
(USANYS)
Subject: RE: focus group exercise
Hi
Attached are the two defense presentations.
Thanks,
From:
Sent: Monday, September 27, 2021 1:36 PM
To:
Cc:
(USANYS)
i
Subject: focus group exercise
Attached is the closing/presentation of government's case that I gave.
and
can send you the presentations
they gave as well. We'll send you a copy of the deliberations when we get the video- let us know where the paras should
mail it.
Everyone is putting together a memo of takeaways from the exercise, so we'll forward that when it's compiled so that you
have the rundown.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint
Plaza
New York, NY 10007
EFTA00011514


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From:
To:
Cc:
Subject: Accepted: Epstein/call in from John Roth
Date: Wed, 11 Jun 2008 15:48:55 +0000
Importance: Normal
Attachments: unnamed
Hi
- I have an 8:30 sentencing with Judge
and then I am headed down to Miami
IfMr
Roth is available later in the morning I could be there live. Otherwise, please call me on my cell,
EFTA00013994


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From:
)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
)"
Subject: RE: Maxwell
Date: Fri, 09 Oct 2020 18:22:28 +0000
Yes, I'm available now until 3 or after 4, thanks.
From:
(USANYS)
Sent: Friday, October 9, 2020 2:22 PM
To:
) ;
(USANYS) ;
(USANYS) ;
-
Subject: RE: Maxwell
ust called with an update. Do some/all of you have time for a quick call? I'm free now until 3 or after 4.
From:
Sent: Friday, October 9, 2020 11:17 AM
To:
(USANYS)
(USANYS)
)
Cc:
(USANYS)
Subject: RE: Maxwell
Thanks very much.
From:
(USANYS)
Sent: Friday, October 9, 2020 11:17 AM
To:
)
;
(USANYS)
)
Cc:
(USANYS)
Subject: FW: Maxwell
Team- both
and
followed up on the review of images from the Epstein devices and FBI assured us that they will
get it done. Please keep us posted and let us know if there is anything else we can do to assist. Thanks!
From:
(USANYS)
Sent: Friday, October 9, 2020 11:10 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: Maxwell
says
get right on the CART issue and make sure it gets done. Let me know what happens.
United States Attorney's Office, SDNY
EFTA00013241


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From:
)"
To:
(USANYS)"
Subject: RE: Meeting tomorrow
Date: Mon, 12 Aug 2019 18:56:24 +0000
Perfect. Will meet you in the lobby.
Original Message
From:
(USANYS)
Sent: Monday, August 12, 2019 2:55 PM
To:
)
Subject: RE: Meeting tomorrow
K, lets say 330?
Original Message
From:
)
Sent: Monday, August 12, 2019 2:54 PM
To:
(USANYS)
Subject: RE: Meeting tomorrow
Yes--free until a call at 5.
Original Message
From:
(USANYS)
Sent: Monday, August 12, 2019 2:52 PM
To:
)
Subject: RE: Meeting tomorrow
You have time for a coffee walk later?
Original Message
From:
)
Sent: Monday, August 12, 2019 2:46 PM
To:
(USANYS)
i
(USANYS)
Cc:
)
i
Subject: RE: Meeting tomorrow
That works, thanks very much.
Original Message
From:
(USANYS)
Sent: Monday, August 12, 2019 2:37 PM
To:
)
i
(USANYS)
Cc:
)
i
Subject: RE: Meeting tomorrow
EFTA00013187

=== Page 2 ===
Definitely. How about 10?
Original Message
From:
)
Sent: Monday, August 12, 2019 2:35 PM
To:
(USANYS)
i
(USANYS)
Cc:
)
i
;
)
Subject: Meeting tomorrow
,
Would you be available to meet to discuss next steps in the Epstein case tomorrow either before 11 or after 2?
Thanks,
EFTA00013188


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Outside juror research
Date: Wed, 17 Nov 2021 04:33:58 +0000
Attachments: 2021.11.16_US_v_Maxwell_Jurors_Proceeding_to_VD-outside_research_&_VD_notes.xlsx
Hi all,
Attached please find the completed research on the next 40 jurors and typed-up VD notes from
and me.
Green highlight indicates starting juror #117 and the 40th juror is highlighted in yellow.
Saved here on the Shared as well.
Best,
From:
Sent: Tuesday, November 16, 2021 7:19 PM
Subject: RE: Outside juror research
f you could please get through the next 40 jurors tonight so the team has whatever research you can
find for voir dire tomorrow, that would be great. Thank you so much!
From:
Sent: Tuesdav. November 16. 2021 6:14 PM
Subject: Outside juror research
Hi team,
have been looking into the jurors proceeding to voir dire (excluding those that were struck today) online,
with many thanks to them. A sample of their notes is attached (which hasn't yet been corroborated by the notes I took
today, which I've sent them-for example, if there's two people with the same name, my notes from today should narrow
it down).
Can you please let
know what would be most helpful to you in advance of tomorrow (e.g., how many
jurors you want them to get through, by what time, etc.)?
Thanks,
EFTA00010043

=== Page 2 ===
Paralegal Specialist
U.S. Attorney's Office
I
SDNY
1 Saint Andrew's Plaza
New York. NY 10007
EFTA00010044


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Tue, 11 Dec 2007 22:20:55 +0000
Importance: Normal
Attachments: 071211
tr_to_Lefkowitz.pdf
I am out today, but I will start pulling everything together tomorrow. We don't have transcripts of all of the state
interviews, but we have audio or videotapes of all of them.
I drafted the attached letter, which I would like to send to Jay.
From: S
Sent: Tuesday, December 11, 2007 5:17 PM
To:
Cc:
Subject: Epstein
In light of the recent Kirkland & Ellis correspondence I've asked
to conduct a de novo review of the evidence
underlying the proposed indictment. I've provided
with the proposed indictment package but can you make copies of
the 302s, state GJ and interview transcripts, and any other underlying investigative information that
can review
a.s.a.p.? Thanks,
EFTA00013537


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: FW: Ghislaine Maxwell 02879-509
Date: Thu, 07 Jan 2021 18:27:23 +0000
FYI
Original Message
From:
Sent: Thursday, January 7, 2021 12:06 PM
To:
BOBBI C STERNHEIM
Cc: Christian Everdell
Mark S. Cohen
)
Subject: Re: Ghislaine Maxwell 02879-509
Good afternoon Bobbi:
We have receive your concerns and will be looking in to these matters.
All concerns will be properly addressed as needed.
Best,
BOBBI C STERNHEIM
1/6/2021 2:38 AM
Counsel for Ghislaine Maxwell learned that she has been issued a disciplinary charge. Please provide a copy of
the Incident Report.
Members of the same team who physically mistreated and threatened Ms.
Maxwell on Sunday now claim that she is not tidy (See email below.) The basis of the charge is unclear -
because Ms. Maxwell has not deviated from her routine of the past 7 months. But the fact that it comes after Ms.
Maxwell and counsel made complaints about staff is concerning, disturbing, and questionable.
The policy of rotating in staff from other institutions has contributed to lack of consistency and clarity in the
management of Ms. Maxwell. One team tells her one thing which is then contradicted by another team.
One team tells her she can't keep books in her locker; another team tells her to put books in her locker. One team
tells her to keep a set of clothes in her isolation cell; another team faults her for doing so.
Ms. Maxwell's request for guidance is met with a terse response: "Read the A&O handbook."
Ms. Maxwell cannot ask other inmates for help and is at the mercy of guards who appear to delight is their
power over her. The present team was particularly harsh during a previous rotation and seem to have increased
their contempt for Ms. Maxwell.
Ms. Maxwell- and counsel- are concerned for her safety while in the custody of the present team.
In lieu of an opportunity for Ms. Maxwell to be moved to another unit, and the unlikelihood that she would be
transferred to the MCC as a result of Epstein's death while BOP was "asleep" on the watch, we are requesting
that the present team be removed from guarding Ms. Maxwell.
Issues still remain concerning Ms. Maxwell's meals. She still is not receiving items on the menu.
Yesterday, she received the same meal for lunch and dinner. Tuesday morning she was given an inedible black
and rotting banana. Over the weekend she was given bologna, despite being on a non-flesh diet. The guard
EFTA00013290

=== Page 2 ===
informed her that the meat had not been refrigerated and recommended that she not eat it.
The MDC's inability to provide proper nutrition is reoccurring and problematic.
The problems keep escalating, giving rise to the belief that Ms.
Maxwell is being targeted and victimized. I urge you to address and correct these problems. The failure to do so
will result in a request for court intervention.
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 Jan 4, 2021, at 7:07 PM, BOBBI C STERNHEIM
wrote:
> Counsel for Ghislaine Maxwell (02879-509) write to report that she
was physically mistreated and verbally threatened by MDC staff over the weekend.
> Officer
(sp) performed a body search of Ms. Maxwell inside her
isolation cell with her back to the handheld camera.
> During the search, Officer
squeezed Ms. Maxwell's breast with
vice-like pressure equivalent to a mammography.
> Ms. Maxwell physically recoiled in response to pain caused by Officer
Another guard, Officer
(sp)
> threatened to charge Ms. Maxwell with "assaulting an officer" should
she move again during a search of her person.
> Ms. Maxwell reported the physical incident to a staff psychologist
and to an associate warden and was examined by
> medical staff. In addition to written reports, the physical and
verbal incidents should have been captured on the hand-held
> camera, used constantly to surveil Ms. Maxwell.
> This is not the first time Ms. Maxwell has been touched
inappropriately by MDC staff, as MDC records should reflect.
V
> Counsel for Ms. Maxwell make this report to put the MDC on notice:
> Should Ms. Maxwell be further assaulted and threatened, we will file
an official complaint with the Attorney General's Office and notify the Court. This will further blemish the
BOP's reputation, already tarnished by negligence resulting in the death of Jeffrey Epstein. The restrictive
conditions of Ms. Maxwell's detention in the MDC correlate directly to the Epstein debacle in the MCC, making
unprovoked rough treatment of Ms. Maxwell baffling.
V
> Be further advised, should Ms. Maxwell face any retaliation as a
EFTA00013291

=== Page 3 ===
result of this email, this too will be promptly reported.
>
> BOBBI C. STERNHEIM, ESQ.
> Law Offices of Bobbi C. Sternheim
V
V
> Main:
> Cell:
> Fax:
V
>> **Covid-19 Notice: The West 19th Street office is currently closed
but we continue to work remotely.
>> Please use email or fax, instead of regular mail, for all
correspondence during this time.
>> We continue to work regular business hours throughout this
situation.
>> Thank you for your consideration. Our best wishes for your good
health and well being.
>
> This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim
> that may be confidential and/or privileged.
> If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
> If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank you.
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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 47 Filed 08/19/19 Page 1 of 1
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 19, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Judge
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
As the Court is aware, on the morning of August 10, 2019, Jeffrey Epstein died while in
custody at the Metropolitan Correctional Center. On August 16, 2019, and after conducting an
autopsy, the Office of the Chief Medical Examiner of the City of New York issued a statement
identifying the cause of death as hanging, and the manner of death as suicide. In light of the death
of the defendant prior to a conviction becoming final, the Government must request the Court
approve the attached proposed order of nolle prosequi.
Consistent with our practice throughout this case and our obligations under the Crime
Victims' Rights Act, the Government has made efforts to contact all identified victims since
learning of the death of the defendant and will similarly notify all known victims of the attached
order, once entered. As this Office has previously stated publicly, it remains committed to doing
its utmost to stand up for the victims who have already come forward, as well as for the many
others who have yet to do so.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
Alison Moe / An Alex Rossmiller / Maurene Comey
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2225 / 2415
Cc:
All counsel of record (Via ECF)
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=== Page 2 ===
Case 1:19-cr-00490-RMB Document 47-1 Filed 08/19/19 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
NOLLE PROSEQUI
UNITED STATES OF AMERICA
:
:
19 Cr. 490 (RMB)
-V.-
:
:
JEFFREY EPSTEIN,
:
:
Defendant.
:
:
X
1. The filing of this nolle prosequi will dispose of
this case with respect to JEFFREY EPSTEIN, the defendant.
2. On July 2, 2019, Indictment 19 Cr. 490 (the
"Indictment") was returned, charging JEFFREY EPSTEIN, the
defendant, with one count of conspiracy to commit sex trafficking
of minors, in violation of 18 U.S.C. § 371, and one count of sex
trafficking of minors, in violation of 18 U.S.C. § 1591.
3. On or about August 10, 2019, while the above-
captioned case was pending, but prior to any trial or other
disposition, JEFFREY EPSTEIN, the defendant, died.
4. Because JEFFREY EPSTEIN, the defendant, died while
this case was pending, and therefore before a final judgment was
issued, the Indictment must be dismissed under the rule of
abatement. See United States V. Wright, 160 F.3d 905, 908 (2d Cir.
1998).
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=== Page 3 ===
Case 1:19-cr-00490-RMB Document 47-1 Filed 08/19/19 Page 2 of 2
5. Accordingly, I recommend that an order of nolle
prosequi be filed as to defendant JEFFREY EPSTEIN.
Dated:
New York, New York
August 19, 2019
An
ALISON MOE / ALEX ROSSMILLER / MAURENE COMEY
Assistant United States Attorneys
Upon the foregoing recommendation, I hereby direct, with
leave of the Court, that an order of nolle prosequi be filed as to
defendant JEFFREY EPSTEIN.
Dated:
New York, New York
August 19, 2019
GEOFFREY S. BERMAN
United States Attorney
Southern District of New York
so ORDERED:
Dated:
New York, New York
August , 2019
Hon. Richard M. Berman
United States District Judge
Southern District of New York
2
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=== Page 1 ===
From:
)"
To:
)"
Subject: FW:
DRAFT 302
Date: Thu, 19 Aug 2021 13:08:56 +0000
Attachments: Interview_Proffer_of
.pdf
From:
Sent: Thursday, August 19, 2021 9:06 AM
To:
)
is
(NY) (FBI)
)
is
(USANYS)
Subject:
DRAFT 302
DRAFT 302
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
EFTA00010385


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOE,
Petitioner.
/
GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION
FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
The United States of America, by and through its undersigned counsel, files its Response to Victim's
Emergency Petition for Enforcement of Victim Rights Act, 18 U.S.C. § 3771, and states:
I. THERE IS NO "COURT PROCEEDING" UNDER 18 U.S.C. § 3771(b)
Petitioner complains that she has been denied her rights under the Crime Victims Rights Act, 18 U.S.C. $
3771. In the emergency petition filed by the victim, she alleges the Government has denied her rights since she
has received no consultation with the attorney for the government regarding possible disposition of the charges
(18 U.S.C. $ 3771(a)(5)); no notice of any public court proceedings (18 U.S.C. $ 3771(a)(2)); no information
regarding her right to restitution (18 U.S.C. $ 3771(a)(6)); and no notice of rights under the Crime Victim Rights
Act (CVRA). Emergency Petition, 1 5.
The instant case is unique in several respects. First, in 2006, Jeffrey Epstein was charged with felony
solicitation of prostitution in the Circuit Court of the Fifteenth Judicial Circuit, Palm Beach County, Florida.
This charge was based upon the offenses alleged in paragraph 1 of the petition. Second, while Epstein has
been under federal investigation, he has not been charged in the Southern District of Florida.
Title 18, U.S.C., section 3771(b)(1) provides in pertinent part that, "[i]n any court proceeding involving
an offense against a crime victim, the court shall ensure that the crime victim is afforded the rights described in
subsection (a)." There is no "court proceeding" in the instant case since Epstein has not been charged with
violation of any federal statute. No federal grand jury indictment has been returned, no has any criminal
information been filed.
In her memorandum, petitioner relies upon In Re Dean , 527 F.3d 391 (5 th Cir. 2008), where the Fifth
Circuit held that the CVRA required the government to "confer in some reasonable way with the victims before
ultimately exercising its broad discretion." Id. at 395. In Dean, the government sought and obtained an ex
parte order permitting it to negotiate a plea agreement with BP Products North America, without first consulting
with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement
was ultimately negotiated and the victims objected. The appellate court found that the CVRA granted a right to
confer. However, the court declined to grant mandamus relief for prudential reasons, finding that the district
EFTA00014077

=== Page 2 ===
court had the benefit of the views of the victims who chose to participate at the hearing held on whether the plea
agreement should be accepted. Id. at 396.
Dean is distinguishable because the government ultimately filed federal criminal charges in that case. In
contrast, no charges have been filed in district court. The only "court proceeding" that has occurred is the one in
state court.
Petitioner argues that "the plain language of the CVRA extends victims' rights to situations 'in which no
prosecution is underway." Petition at 5, citing 18 U.S.C. $ 3771(d)(3). Section 3771(d)(3) provides, in
pertinent part, that:
The rights described in subsection (a) shall be asserted in the district court in
which a defendant is being prosecuted for the crime or, if no prosecution is
underway, in the district court in the district in which the crime occurred
This provision does not set forth when rights under CVRA accrue, but only designates the venue in which
enforcement of any rights may occur. Congress has provided a venue for the assertion of purported rights under
the CVRA, but because it provided for a venue for instances where no prosecution is underway, does not mean it
intended to grant such rights. Certain rights granted under 18 U.S.C. 3771(a) likely do apply prior to the
initiation of a federal criminal proceeding, such as the right to be reasonably protected from the accused (§
3771(a)(1)), and the right to proceedings free from unreasonable delay (§ 3771(a)(7)). It is also clear that other
rights in $ 3771(a) only apply after criminal proceedings have been initiated, since they refer to a "public court
proceeding" or "public proceeding." § 3771(a)(2), (3), and (4). Whether $ 3771(a)(5), the reasonable right to
confer with the attorney for the Government in the case, applies in cases where a federal criminal proceeding is
neither commenced nor even contemplated, can only be answered by looking to the text in § 3771(a), not the
enforcement provision in § 3771(d)(3). Nothing in § 3771(a)(5) supports the petitioner's claim that she had a
right to be consulted before the Government could enter into a non-prosecution agreement which defers federal
prosecution in exchange for state court resolution of criminal liability, and a significant concession on an element
of a claim for compensation under 18 U.S.C. § 2255.
II. THE GOVERNMENT HAS USED ITS BEST EFFORTS TO COMPLY WITH 18 U.S.C. § 3771(a)
The Epstein case was investigated initially by the Palm Beach Police Department in 2006. Exhibit A,
Declaration of Assistant United States Attorney
12. Subsequently, the Palm Beach Police
Department sought the assistance of the Federal Bureau of Investigation (FBI). Id. Throughout the
investigation, when a victim was identified, victim notification letters were provided to the victim by both the
FBI Victim-Witness Specialist and AUSA
Id. 3. Petitioner's counsel, Brad Edwards, Esq.,
currently represents
and
The victim notification letter to
was hand-delivered by FBI agents.
EFTA00014078

=== Page 3 ===
The letter to
was hand-delivered by AUSA
to her when she was interviewed in
,
2007.
Throughout the investigation, AUSA
and the FBI's Victim-Witness Specialist had contact with
Decl.,
1
4.
Earlier in the investigation,
was represented by James Eisenberg, Esq.
Consequently, all contact with
was made through Mr. Eisenberg.
In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to resolve the federal
investigation. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of
prostitution, in violation of Florida Statutes $ 796.07. Mr. Epstein's attorneys sought a global resolution of this
matter. The United States subsequently agreed to defer federal prosecution in favor of prosecution by the State
of Florida, so long as certain basic preconditions were met. One of the key objectives for the Government was to
preserve a federal remedy for the young girls which Epstein had sexually exploited. Thus, one condition of that
agreement, notice of which was provided to the victims on July 9, 2008, is the following:
"Any person, who while a minor, was a victim of a violation of an offense
enumerated in Title 18, United States Code, Section 2255, will have the
same rights to proceed under Section 2255 as she would have had, if Mr.
Epstein had been tried federally and convicted of an enumerated offense.
For purposes of implementing this paragraph, the United States shall
provide Mr. Epstein's attorneys with a list of individuals whom it was
prepared to name in an Indictment as victims of an enumerated offense by
Mr. Epstein. Any judicial authority interpreting this provision, including any
authority determining which evidentiary burdens if any a plaintiff must
meet, shall consider that it is the intent of the parties to place these identified
victims in the same position as they would have been had Mr. Epstein been
convicted at trial. No more; no less."
The Attorney General Guidelines for Victim and Witness Assistance (May 2005), Article IV, Services to
Victims and Witnesses, provides the following guidance for proposed plea agreements:
(3) Proposed Plea Agreements. Responsible officials should make reasonable efforts to notify
identified victims of, and consider victims' views about, prospective plea negotiations. In
determining what is reasonable, the responsible official should consider factors relevant to the
wisdom and practicality of giving notice and considering views in the context of the particular
case, including, but not limited to, the following factors:
(a) The impact on public safety and risks to personal safety.
(b) The number of victims.
(c) Whether time is of the essence in negotiating or entering a proposed plea.
(d) Whether the proposed plea involves confidential information or conditions.
(e) Whether there is another need for confidentiality.
(f) Whether the victim is a possible witness in the case and the effect that relaying any information may
have on the defendant's right to a fair trial.
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=== Page 4 ===
Throughout negotiations, Epstein's attorneys claimed that one reason victims came forward and pressed
their claims was their desire for money. They argued that victims might have an inducement to fabricate or
enhance their testimony, in order to maximize their opportunities to obtain financial recompense. The
Government was extremely concerned that disclosure of the proposed terms would compromise the investigation
by providing Epstein the means of impeaching the victim witnesses, should the parties fail to reach an
agreement. In light of the fact (i) that the United States agreed to defer prosecution to a previously filed state
criminal case; (ii) that as a result sentencing would take in state court before a state judge; (iii) that if the state
resolution failed to meet minimum standards such that a federal prosecution was warranted, the victims would be
witnesses and thus potential impeachment issues were of concern; and, (iv) the United States was already
making efforts to secure for victims the right to proceed federally under 18 U.S.C. $ 2255, even if prosecution
took place in state court, the Government determined that its actions in proceeding with this agreement best
balanced the dual position of the Jane Does as both victims and potential witnesses in a criminal proceeding.
On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA
received a copy of the proposed
state plea agreement, and learned the plea hearing was scheduled for Monday, June 30, 2008, at 8:30 a.m.
Decl., 18. AUSA
the FBI agents, and the Palm Beach Police Department, all attempted
to provide notification to the victims. Id. AUSA
called attorney Edwards to provide notice to his
clients regarding the hearing. AUSA
did this, even though she had no obligation to provide notice of
a state court hearing. Mr. Edwards advised that he could not attend but that someone would be present at the
hearing. Id.
The Government has complied with 18 U.S.C. $ 3771(c)(1) by using its best efforts to "see that crime
victims are notified of, and accorded, the rights described in subsection (a)." Specifically, petitioner was
afforded the reasonable right to confer with the attorney for the Government under 18 U.S.C. $ 3771(a)(5).
Disclosure of the specific terms of the negotiation were not disclosed prior to a final agreement being reached
because the Government believed doing so would jeopardize and prejudice the prosecution in the event an
agreement could not be made. Insofar as notice of any public court proceedings under 18 U.S.C. $ 3771(a)(2),
petitioner's counsel was notified on June 27, 2008, of the plea hearing in state court on June 30, 2008.
Section 3771(d)(6) provides, in relevant part, that "[n]othing in this chapter shall be construed to impair
the prosecutorial discretion of the Attorney General or any officer under his direction." The Government
exercised its judgment and discretion in determining that there was a need for confidentiality in the negotiations
with Epstein. The significant benefit of obtaining Epstein's concession that victims suing him under 18 U.S.C.
EFTA00014080

=== Page 5 ===
§ 2255(a) were "victims" of the enumerated offenses, despite the fact he has not been convicted in federal court,
was of sufficient importance to justify confidentiality of the negotiations.
Petitioner's rights under the CVRA have not been violated. Therefore, her emergency petition should be
denied.
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From: "Acosta, Alex (USAFLS)"
To:
Subject:
- I shouldn't be part of the epstein emails, for obvious reasons.
Date: Sun, 23 Nov 2008 15:21:26 +0000
Importance: Normal
EFTA00013594


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=== Page 1 ===
From:
To:
(USAFLS)"
i
Subject: Article today about Epstein plea
Date: Thu, 03 Jan 2008 16:06:34 +0000
Importance: Normal
Attachments: Jan_3_2008_Palm_Beach_Daily_News_Article.pdf
Hi
and
- FYI
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
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=== Page 1 ===
From:
To:
Subject: Epstein review
Date: Wed, 04 Sep 2019 15:03:28 +0000
Importance: Normal
Hi
Do you happen to know how much data was on the drive we gave you last week? Just trying to get a sense of the
scale of the anticipate review.
Thanks!
Sent from my iPhone
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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 22:06:19 +0000
Date Modified: 2020-05-21 22:06:19 +0000
Priority: 5
DTSTAMP: 2020-05-21 21:43:03 +0000
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=== Page 1 ===
From:
To:
Subject: RE:
Date: Thu, 27 Jun 2019 13:54:23 +0000
Importance: Normal
Sure.
never called me back - I'm going to give him another 30 minutes or so then try him again.
Original Message
From:
Sent: Thursday, June 27, 2019 9:53 AM
To:
Subject:
Should we set up a meeting with us,
and our Epstein teams on Monday to discuss op plans?
Sent from my iPhone
EFTA00010574


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Relativity Access -- Epstein SW Database
Date: Fri, 04 Dec 2020 19:24:28 +0000
Attachments: EOUSA_MEGA4_Account_Request_and_ROB_Form.pdf
Hello,
Please have the agent fill out the attached form. I will also need to know if the she has an IPhone or Android phone as it is
needed for the RSA token.
Thank you.
From:
Sent: Friday, December 4, 2020 2:19 PM
To
Subject: Relativity Access -- Epstein SW Database
Hi
Could you please assist us in obtaining a Relativity token for
an FBI analyst working on this case with us?
is copied here.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 330 Filed 08/27/21 Page 1 of 2
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/27/21
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On May 11, 2021, the Court informed the parties that it set a tentative trial date for
November 29, 2021. The Court accordingly requested a jury trial for that date pursuant to the
COVID rules for centralized jury trial scheduling in the district. The Clerk's Office has now
confirmed that a jury trial in this case has been scheduled to commence on November 29, 2021.
This is a firm trial date. When the information is available, the Court will provide courtroom
location and public access information by separate order.
Due to space limitations resulting from the SDNY COVID protocols, the Clerk's Office
has also provided the following dates for administering a juror questionnaire and conducting voir
dire: November 4, 5, and 12 (questionnaire), and November 16-19 (voir dire). The Court
intends to use a streamlined questionnaire as much as feasible given all relevant circumstances.
The parties shall bear this in mind when they discuss and jointly propose a questionnaire and voir
dire on the schedule outlined below.
In light of the firm dates discussed above, it is hereby ORDERED that the parties appear
for a telephone conference to discuss jury selection matters on October 21, 2021 at 12:00 P.M.
Dial-in information for the parties and for public access will be provided when it is available by
separate order.
1
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=== Page 2 ===
Case 1:20-cr-00330-AJN Document 330 Filed 08/27/21 Page 2 of 2
In light of the jury selection dates provided by the Clerk's Office, the Court amends the
schedule that it set on June 2, 2021 as follows. The parties shall meet and confer and submit a
joint proposed juror questionnaire and joint proposed voir dire by October 11, 2021. The parties
shall file a joint proposed charge and verdict sheet, with any differing proposals supported by
authority or other justification, by October 27, 2021. Any motions in limine must be
simultaneously filed by October 18, 2021, and any responses to motions in limine are due by
October 25, 2021. Otherwise, the parties shall continue to follow the schedule that the Court set
on June 2, 2021. Dkt. No. 297.
IT IS FURTHER ORDERED that the parties appear for an in-person pretrial conference
on November 1, 2021 at 11:00 A.M. Location information and public access information will
be provided by separate order when available.
so ORDERED.
Dated: August 27, 2021
Alim Netto
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From: "
(USAFLS)"
To:
(USAFLS)"
Subject: RE: A new lawsuit against Epstein
Date: Wed, 06 Feb 2008 21:40:10 +0000
Importance: Normal
Have there been any other vaguely threatening communications from Jay, et al?
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
From:
(USAFLS)
Sent: Wednesday, February 06, 2008 4:39 PM
To:
(USAFLS)
Subject: RE: A new lawsuit against Epstein
I saw it.
South Florida Sun-Sentinel.com
Palm Beach billionaire faces second sex-assault lawsuit
By Nancy Othón
Sun-Sentinel.com
12:01 PM EST, February 6, 2008
Billionaire and part-time Palm Beach resident Jeffrey Epstein was sued for the second time in less than two
weeks Wednesday, this time by another teenager who claims she was sexually abused at his mansion.
The 16-year-old Virginia girl is represented by the same attorney who filed a $50 million federal lawsuit in late
January against Epstein, 55. This lawsuit seeks similar damages for an alleged sexual assault and intentional
infliction of emotional distress.
Jeffrey Herman, the teen's attorney, is planning a news conference in West Palm Beach this afternoon to discuss
the allegations.
EFTA00013776

=== Page 2 ===
Epstein, arrested in 2006 on a felony charge of solicitation of prostitution, is scheduled to appear in court next
month for a status hearing. The New York resident is accused of luring young girls to his mansion for massages
that turned sexual.
The lawsuit alleges that Epstein has a sexual preference and "obsession for underage minor girls" and sought to
gain access to economically disadvantaged younger girls in his home for paid massages.
The 16-year-old girl, identified in the lawsuit as "Jane Doe No. 2," has suffered traumatic injuries, according to
the complaint.
When the first lawsuit was filed Epstein's attorneys said Epstein never had sex with the girl, who was 14 at the
time, and that the lawsuit was motivated by greed.
From:
(USAFLS)
Sent: Wednesday, February 06, 2008 4:37 PM
To:
(USAFLS)
Subject: A new lawsuit against Epstein
Hi
- Herman filed another lawsuit on behalf of a girl from Virginia. I do not think that it is one of our girls.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax 561 820-8777
EFTA00013777


c1: EFTA00013189
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0001/EFTA00013189.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(OIG)"
i
(NY) (FBI)"
i
,
(NY) (OGA) (FBI)"
"
(NY) (FBI)"
Subject: Update Conference Call - Epstein
Date: Tue, 13 Aug 2019 00:09:53 +0000
Importance: Normal
Attachments: unnamed
+1
Conference ID: 227558
EFTA00013189


c1: EFTA00013466
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c0:
=== Page 1 ===
Event: Hearing on Epstein Motion to Quash
Start Date: 2007-09-18 13:00:00 +0000
End Date: 2007-09-18 16:00:00 +0000
Organizer:
Location: Judge Marra
Class: X-PERSONAL
Date Created: 2015-03-27 13:42:56 +0000
Date Modified: 2015-07-22 20:34:49 +0000
Priority: 5
DTSTAMP: 2007-09-11 16:13:46 +0000
Attendee:
EFTA00013466


c1: EFTA00011494
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=== Page 1 ===
From:
"
To:
"
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: Re: OPR Epstein Final Report
Date: Fri, 29 Jan 2021 22:33:12 +0000
Embedded: Re:_OPR_Epstein_Final_Report.msg
Sender:
Subject: Re: OPR Epstein Final Report
Message-Id: <78942A34-AB70-45F7-9B8D-31EBF8377A48@usa.doj.gov>
To:
Cc:
EFTA00011494


c1: EFTA00011445
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=== Page 1 ===
EXHIBIT A
EFTA00011445

=== Page 2 ===
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 1 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 2 of 7
United States District Court
Southern District Of New York
X
Plaintiff,
DATE FILES
3/18/16
v.
15-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
X
PROTECTIVE ORDER
Upon a showing of good cause in support of the entry of a protective order to
protect the discovery and dissemination of confidential information or information which
will improperly annoy, embarrass, or oppress any party, witness, or person providing
discovery in this case, IT IS ORDERED:
1.
This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and other
information disclosed pursuant to the disclosure or discovery duties created by
the Federal Rules of Civil Procedure.
2.
As used in this Protective Order, "document" is defined as provided in
FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document
within the meaning of this term.
EFTA00011446

=== Page 3 ===
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 2 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 3 of 7
3.
Information designated "CONFIDENTIAL" shall be information that is
confidential and implicates common law and statutory privacy interests of (a)
plaintiff
and (b) defendant Ghislaine Maxwell.
4.
CONFIDENTIAL information shall not be disclosed or used for any purpose
except the preparation and trial of this case.
5.
CONFIDENTIAL documents, materials, and/or information (collectively
"CONFIDENTIAL INFORMATION") shall not, without the consent of the
party producing it or further Order of the Court, be disclosed except that such
information may be disclosed to:
a. attorneys actively working on this case;
b. persons regularly employed or associated with the attorneys actively
working on this case whose assistance is required by said attorneys in the
preparation for trial, at trial, or at other proceedings in this case;
c. the parties;
d. expert witnesses and consultants retained in connection with this
proceeding, to the extent such disclosure is necessary for preparation, trial
or other proceedings in this case;
e. the Court and its employees ("Court Personnel") in this case;
f. stenographic reporters who are engaged in proceedings necessarily incident
to the conduct of this action;
g. deponents, witnesses, or potential witnesses; and
2
EFTA00011447

=== Page 4 ===
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 3 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 4 of 7
h. other persons by written agreement of the parties.
6.
Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel, persons employed by counsel, Court
Personnel and stenographic reporters), counsel shall provide such person with
a copy of this Protective Order and obtain from such person a written
acknowledgment stating that he or she has read this Protective Order and
agrees to be bound by its provisions. All such acknowledgments shall be
retained by counsel and shall be subject to in camera review by the Court if
good cause for review is demonstrated by opposing counsel.
7.
Documents are designated as CONFIDENTIAL by placing or affixing on them
(in a manner that will not interfere with their legibility) the following or other
appropriate notice: "CONFIDENTIAL." Discovery material designated
CONFIDENTIAL shall be identified by Bates number. To the extent practical,
the respective legend shall be placed near the Bates number.
8.
Designation of a document as CONFIDENTIAL INFORMATION shall
constitute a representation that such document has been reviewed by an
attorney for the designating party, that there is a valid and good faith basis for
such designation, made at the time of disclosure or production to the receiving
party, and that disclosure of such information to persons other than those
permitted access to such material would cause a privacy harm to the
designating party.
3
EFTA00011448

=== Page 5 ===
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 4 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 5 of 7
9.
Whenever a deposition involves the disclosure of CONFIDENTIAL
INFORMATION, the deposition or portions thereof shall be designated as
CONFIDENTIAL and shall be subject to the provisions of this Protective
Order. Such designation shall be made on the record during the deposition
whenever possible, but a party may designate portions of depositions as
CONFIDENTIAL after transcription, provided written notice of the
designation is promptly given to all counsel of record within thirty (30) days
after notice by the court reporter of the completion of the transcript, and until
the expiration of such thirty (30) days after notice by the court reporter of the
completion of the transcript, no party or counsel for any such party may share
the contents of the deposition outside the limitations of this Protective Order.
10.
Whenever a party seeks to file any document or material containing
CONFIDENTIAL INFORMATION with the Court in this matter, it shall be
accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic
Case Filing Rules & Instructions for the Southern District of New York.
11.
A party may object to the designation of particular CONFIDENTIAL
INFORMATION by giving written notice to the party designating the disputed
information. The written notice shall identify the information to which the
objection is made. If the parties cannot resolve the objection within ten (10)
business days after the time the notice is received, it shall be the obligation of
the party designating the information as CONFIDENTIAL to file an
4
EFTA00011449

=== Page 6 ===
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 5 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 6 of 7
appropriate motion requesting that the Court determine whether the disputed
information should be subject to the terms of this Protective Order. If such a
motion is timely filed, the disputed information shall be treated as
CONFIDENTIAL under the terms of this Protective Order until the Court rules
on the motion. If the designating party fails to file such a motion within the
prescribed time, the disputed information shall lose its designation as
CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in
accordance with this Protective Order. In connection with a motion filed under
this provision, the party designating the information as CONFIDENTIAL shall
bear the burden of establishing that good cause exists for the disputed
information to be treated as CONFIDENTIAL.
12.
At the conclusion of this case, unless other arrangements are agreed upon, each
document and all copies thereof which have been designated as
CONFIDENTIAL shall be returned to the party that designated it
CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL
documents. Where the parties agree to destroy CONFIDENTIAL documents,
the destroying party shall provide all parties with an affidavit confirming the
destruction.
13. This Protective Order shall have no force and effect on the use of any
CONFIDENTIAL INFORMATION at trial in this matter.
5
EFTA00011450

=== Page 7 ===
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 6 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 7 of 7
14.
This Protective Order may be modified by the Court at any time for good cause
shown following notice to all parties and an opportunity for them to be heard.
Grout BY THE COURT
UNITED/STATES DISTRICT JUDGE
3-17-16
6
EFTA00011451


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=== Page 1 ===
From: "Strauss, Audrey (USANYS)"
To:
(USANYS)"
Subject: Bruce Green/Judge Berman exchanged letters
Date: Wed, 04 Sep 2019 20:53:15 +0000
Importance: Normal
Attachments: Professor_Green_letter,_19_Cr_490.pdfJudge_Berman_letter_19_Cr_490.pdf
Ted reports that both letters have been docketed.
From:
(USANYS)
Sent: Wednesday, September 4, 2019 4:48 PM
To: Strauss, Audrey (USANYS)
Subject:
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00011024


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein Editorial
Date: Fri, 16 Nov 2007 20:42:32 +0000
Importance: Normal
Attachments: Epstein_Article.pdf
- The editor of the Palm Beach Post seems to be putting Mr. Krischer on notice that they are watching and
waiting.
Assistant U.S. Attorney
EFTA00013629


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=== Page 1 ===
From:
USANYS)
To:
(USANYS)"
)"
Bcc:
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Date: Fri, 08 Jan 2021 00:05:18 +0000
Embedded: RE:_Epstein_FOIA_case,_Times_v_BOP_20-cv-833.msg
Sender:
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Message-Id:
<BN3P110MB041928118FF9016066053EB1FBAE0@BN3P110MB0419.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
EFTA00013299


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=== Page 1 ===
From:
To: Gary Bloxsome
Cc:
Daniel Cundy
Jennifer Richardson
Subject: RE: Reference materials further to our call
Date: Wed, 23 Sep 2020 22:37:35 +0000
Inline-Images: image001.jpg; image002.jpg
Dear Gary,
Thank you for your email of September 16, 2020. We understand that your client has declined to sit for a voluntary
interview and provide oral answers in real time to our office. Because the written statement you propose to provide will
not assist our investigation, we intend to move forward with our MLA request seeking a compelled interview of your
client. Accordingly, we plan to inform the UKCA that the parties are not able to reach agreement on a voluntary interview
and that a voluntary interview will not occur.
Best regards,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
York
NV
10007
From: Gary Bloxsome
Sent: Wednesday, September 16, 2020 2:52 AM
To:
Cc:
Daniel Cundy ; Jennifer Richardson
Subject: Re: Reference materials further to our call
Dear
I believe my response is clear. The Duke of York will provide a witness statement and will agree, following the provision of
that witness statement, to a voluntary written interview wherein he will answer any and all relevant questions of him as a
witness in writing about the full range of topics relevant to your ongoing investigation, including events not covered by
the currently pending indictment against Ghislaine Maxwell. If you want to ask any questions in person or via video rather
than in writing I am sure the Duke would be willing to receive your questions in that format before providing written
answers.
Kind regards
Gary
Garv Bloxsome Partner
RANKED IN
Chambers
UK
500
KINGDOM
2020
TOP TIER
Leading Firm
2020
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
EFTA00010321

=== Page 2 ===
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020
8686 6232 where we will respond to the messages in the order they are received or by emailing your
enquiry to covid@blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 14 Sep 2020, at 16:56
wrote:
External email: is it safe to open attachments and links?
Dear Gary,
Thank you for your email, and I hope you are well, too.
Your response does not address two outstanding questions. First, will your client participate in a voluntary interview,
either in person or via video, with our office? Second, will your client answer questions - in writing or otherwise -- about
the full range of topics relevant to our ongoing investigation, including events not covered by the currently pending
indictment against Ghislaine Maxwell?
Please note that we will interpret a repeat of your client's offer to answer written questions relevant to the Maxwell
indictment as an answer in the negative as to both questions.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gary Bloxsome
Sent: Monday, September 14. 2020 5:39 AM
To:
Cc:
Daniel Cundy
Jennifer
Richardson
is
Subject: Re: Reference materials further to our call
Dear
Hope you are well.
Thank you for your email of September 10, 2020. We cannot confirm your understanding in the summary form that you
present it.
Our client has offered voluntarily to provide a written witness statement in relation to the criminal indictment against
Ghislaine Maxwell and has also offered to answer questions in writing in relation to events relevant to that indictment
even if they fall outside of the period of the indictment (1994 to 1997).
We look forward to hearing from you further.
Kind regards
Gary
Gary Bloxsome I Partner
EFTA00010322

=== Page 3 ===
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020
8686 6232 where we will respond to the messages in the order they are received or by emailing your
enquiry to covid@blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 10 Sep 2020, at 21:00,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
Thank you for your email of September 1, 2020. We would like to confirm our understanding of that correspondence,
as informed by all of our communications over the past few months, as conveying that (1) your client will not
participate in a voluntary interview-either in person or via videoconference-with our office, and (2) that your client
will not voluntarily answer questions, even as part of a written statement, regarding events that took place outside of
the period 1994 to 1997. Please let us know if our understanding is incorrect.
Thank you
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
From:
Sent: Tuesday, September 1, 2020 1:35 PM
To: Gary Bloxsome
; Daniel Cundy
Jennifer
Richardson
Co
Subject: RE: Reference materials further to our call
Gary,
We have received the below communication, and we will revert back as appropriate.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Tuesday, September 01, 2020 13:04
To:
Daniel
EFTA00010323

=== Page 4 ===
Cundy
Jennifer Richardson
Subject: Re: Reference materials further to our call
Dear
We have found our recent conferences with you and your team (on 27 July, 3, 11 and 20 August 2020) helpful and
informative and again I extend my thanks for your taking the time to discuss these matters at length.
In the UK the provision of a signed witness statement - bearing a statement attesting as to its truth - is a commonly
used approach when a witness provides evidence. Whilst we appreciate that such an approach differs from what is
standard in the US, we do not consider such an approach would be unhelpful, or of no utility, to your case. Our client is
willing to provide you with a witness statement, addressing any issues that he may be able to,in relation to Ghislaine
Maxwell and Jeffrey Epstein, his association with them and his knowledge of them such as may be relevant to the
prosecution of Ghislaine Maxwell. In addition - should you make written requests for clarification arising from that
witness statement - our client could provide written answers by way of a supplementary/addendum statement. Such
an interaction could take place more than once if necessary. Providing written answers to either written questions or
to questions previously put, is again a common practice in the UK.
You have invited us to identify any areas or subject topics which we would consider to be inappropriate or irrelevant to
be put to our client; we consider that questions put/topics raised should rightfully be limited to the indictment period
in the current proceedings (i.e. US V Ghislaine Maxwell), being 1994-1997.
We are of course aware that you have requested a witness interview in your request to the UKCA and to ourselves; you
have confirmed to us however (in January this year, through your liaison officer immediately prior to our recent
conferences, and then during our conferences) that you regard our client not as a witness but as a subject. We have
ventilated at some length our concerns regarding our client being interviewed in those circumstances and we consider
a witness statement and the offer of further engagement with written questioning to be a fair compromise and one
which would be acceptable in the UK.
To move forward with the above approach, we would continue to require your assurance that the content of any such
witness statement and supplementary written responses be treated with the utmost confidentiality, not used for any
purpose other than in relation to the criminal proceedings against Ms Maxwell, and not be shared with any parties
outside of your department, including complainants and their representatives in your investigation and in civil matters
outside of it.
Kind regards
Gary
Gary Bloxsome
Partner
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020
8686 6232 where we will respond to the messages in the order they are received or by emailing your
enquiry to covid@blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 19 Aug 2020, at 18:19,
wrote:
EFTA00010324

=== Page 5 ===
External email: is it safe to open attachments and links?
Received, thank you. We'll speak with you then.
From: Gary Bloxsome
Sent: Wednesday, August 19, 2020 12:39
To:
Cc:
Jennifer
Richardson
; Daniel Cundy
Subject: Re: Reference materials further to our call
Yes
Same dial in details as before.
Regards
Gary Bloxsome I Partner
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020
8686 6232 where we will respond to the messages in the order they are received or by emailing your
enquiry to covid@blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 19 Aug 2020, at 17:36,
wrote:
External email: is it safe to open attachments and links?
Gary,
Are we still planning to speak via phone tomorrow at 2:30 London time?
Regards,
From: Daniel Cundy
Sent: Sunday, August 09, 2020 12:30
To:
Cc:
Gary
Bloxsome
Jennifer Richardson
Subject: Reference materials further to our call
Dear
Apologies for the slight delay.
Please find attached an extract from The Decision Procedure and Penalties manual (DEPP 7) from the Financial
Conduct Authority handbook - drawing attention to 7.2.14. This practice and approach resonates with the law as
set out in United States V. Allen, 864 F.3d (2d Cir.2017). We also attach an extract from the publication
EFTA00010325

=== Page 6 ===
'Montgomery and Ormerod on Fraud: Criminal Law and Procedure' (2008) which summarises the approach taken
by the Serious Fraud Office (see A7-327) to the limitations and protections on use when their compulsory powers
are used in MLAT requests, an approach which reflects such cases as Kastigar V. United States, 406 U.S. 441 (1972)
as well as decisions in UK domestic law. We reiterate the protection at Article 7 (2) of the MLAT treaty although
there is no need to attach it.
Kind regards
Daniel Cundy Partner
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020
8686 6232 where we will respond to the messages in the order they are received or by emailing your
enquiry to covid@blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
Daniel Cundy I Partner
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020
8686 6232 where we will respond to the messages in the order they are received or by emailing your
enquiry to covid@blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00010326


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c0:
=== Page 1 ===
From: "Acosta, Alex (USAFLS)" <AAcosta@usa.doj.gov>
To:
Subject: Read: Epstein
Date: Fri, 21 Nov 2008 16:22:38 +0000
Importance: Normal
EFTA00013593


c1: EFTA00009988
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=== Page 1 ===
Exhibit C
EFTA00009988

=== Page 2 ===
INVOICE #
DATE
ACCT #
0-008-75783
9/23/2005
229207504
1-510-70083
12/19/2003
229207504
1-511-12508
12/26/2003
229207504
1-520-10533
12/15/2003
114420816
1-520-23635
12/15/2003
114420816
1-520-53636
12/15/2003
114420816
1-520-54564
12/22/2003
114420816
1-520-59644
12/22/2003
114420816
1-520-95145
12/29/2003
114420816
1-521-05034
12/29/2003
114420816
1-521-28589
1/5/2004
114420816
1-521-37706
1/5/2004
114420816
1-521-62031
1/12/2004
114420816
1-521-73658
1/12/2004
114420816
1-558-21719
1/16/2004
229207504
1-559-14625
2/2/2004
229207504
1-559-23435
1/30/2004
229207504
1-559-71155
2/6/2004
229207504
1-568-02887
1/19/2004
114420816
1-568-12826
1/19/2004
114420816
1-568-42847
1/26/2004
114420816
1-568-60389
1/26/2004
114420816
1-568-96363
2/4/2004
114420816
1-569-15758
2/2/2004
114420816
1-569-52490
2/6/2004
114420816
1-569-71267
2/9/2004
114420816
1-596-42828
2/9/2000
181497793
1-606-30926
2/16/2004
229207504
1-607-48682
3/1/2004
229207504
1-616-10233
2/16/2004
114420816
1-616-30911
2/16/2004
114420816
1-616-69056
2/23/2004
114420816
1-616-88199
2/23/2000
114420816
1-617-24260
3/1/2004
114420816
1-617-45296
3/1/2004
114420816
1-617-80478
3/8/2004
114420816
1-617-98318
3/8/2004
114420816
1-646-19156
3/1/2004
181497793
1-647-36442
3/15/2004
181497793
1-654-03201
3/8/2004
229207504
1-654-65250
3/15/2004
229207504
1-655-26527
3/19/2004
229207504
1-655-85349
3/29/2000
229207504
1-655-95220
3/26/2004
229207504
1-664-41268
3/15/2004
114420816
1-664-61773
3/15/2004
114420816
EFTA00009989

=== Page 3 ===
1-859-10707
1-858-72484
1-858-51975
1-858-12740
1-847-51358
1-846-39927
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=== Page 4 ===
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=== Page 5 ===
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=== Page 7 ===
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=== Page 8 ===
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=== Page 9 ===
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=== Page 10 ===
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=== Page 11 ===
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=== Page 12 ===
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=== Page 13 ===
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=== Page 14 ===
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=== Page 15 ===
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=== Page 17 ===
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=== Page 18 ===
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=== Page 19 ===
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11/22/2004
11/19/2000
11/15/2004
11/8/2004
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11/1/2004
11/1/2004
10/26/2004
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10/18/2004
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7/29/2005
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8/15/2005
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8/1/2005
7/25/2005
7/18/2005
7/11/2005
7/5/2005
6/27/2005
6/20/2005
6/10/2005
6/3/2005
6/13/2005
6/6/2005
5/31/2005
114420816
114420816
229207504
114420816
229207504
114420816
114420816
114420816
229207504
114420816
229207504
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229207504
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229207504
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181497793
181497793
181497793
229207504
114420816
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229207504
229207504
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EFTA00010006

=== Page 20 ===
7-932-67997
12/31/2004
229207504
7-934-27583
1/3/2005
114420816
7-943-27562
1/7/2005
229207504
7-945-01052
1/10/2005
114420816
7-957-57908
1/17/2005
114420816
7-969-99868
1/24/2005
114420816
7-980-61298
1/28/2005
229207504
7-982-39156
1/31/2005
114420816
7-992-78298
2/4/2005
229207504
7-994-59177
2/7/2005
114420816
7-995-13549
2/7/2005
181497793
8-029-74828
1/4/2007
114420816
8-042-73096
2/5/2007
114420816
8-073-08144
4/17/2007
114420816
8-359-79450
9/25/2006
114420816
8-825-06174
9/30/2005
229207504
8-825-16920
10/7/2005
229207504
8-826-02827
10/3/2005
114420816
EFTA00010007


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=== Page 1 ===
From: "KATHERINE W. EZELL"
To:
(USAFLS)"
Subject: RE:
Date: Mon, 29 Dec 2008 23:11:12 +0000
Importance: Normal
Thanks,
From:
(USAFLS) [mailto:
Sent: Monday, December 29, 2008 5:05 PM
To: KATHERINE W. EZELL
Cc: Amy Ederi
Subject: RE:
Hi Kathy and Amy - I hope all is well with you. I see from the paper that you are in a firestorm of your own
right now.
I just spoke with
He said that if you provide the address info, it will not be disclosed to Epstein
or his people. Epstein is accompanied only by his private driver when he goes to and from the jail, although
PBSO has his travel routes programmed in to his GPS monitor so, if he deviates from that route, they will know
if they check the monitor when he returns.
has asked that all requests go through me so he knows who is legit and who isn't, so if anyone
wants their addres(es) added, please let me know. I am going to send an e-mail to all of the plaintiffs' attorneys
with this info.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
From: KATHERINE W. EZELL [mailto:
Sent: Monday, December 29, 2008 1:44 PM
To:
(USAFLS)
Cc: Amy Ederi
Subject:
Dear
,
This is a message I tried to send on the 20th. I got a notification back that it did not go through, so I'm trying
this different address.
In your notification letter about JE's work release that you wrote to the victims you mentioned the possibility of their
notifying you if they wanted any of their addresses made off limits on his mechanical device that restricts him. First, if he is
only going to and from that office address, why does he need to be mechanically otherwise restricted? Second, should one
of the victims want to designate an address where she lives or works to be programmed as off limits, is it possible for him
to then have access to the name of the victim and the specific location from which he is being restricted?
Wishing you a peaceful and happy holiday! Kathy
EFTA00014128


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=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter Motion
Date: Fri, 12 Nov 2021 21:29:33 +0000
Attachments: 2021-11-12_GM_clarification_letter_[proposed_redactions]pdf;2021-11-
12_GM_clarification_letter_[unredacted].pdf
Chambers,
Attached please find an unredacted copy of the Government's letter motion filed today (Dkt. No. 455), along with a copy
highlighting the Government's proposed redactions.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00010036


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 20, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing
copies of the materials listed in the below index, which materials are stamped with control numbers
SDNY GM 00328070 through SDNY_GM_00356148. The password for the drive is
The materials are available for pickup at the U.S. Attorney's Office in Manhattan.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
1 Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format. Such files include in their electronic names the
word "Confidential."
06.20.2018
EFTA00027072

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential
Designation
2020.07.02, Aerial Video
SDNY_GM_00328073
FBI Florida Documents
Confidential
SDNY_GM_00328093
SDNY_GM_00328289
FBI NY Documents
06787800 WD ANCS
SDNY_GM_00328461
Misc. Photos
Confidential
900 ANGS
SDNY_GM_00328667
PBPD Materials
SDNY_GM_00329968
PBPD Materials
Confidential
69667800 WD ANCS
SDNY_GM_00330052
PBPD Materials
Highly Confidential
SDNY_GM_00330053
SDNY_GM_00332355
PBSA Materials
Confidential
SDNY_GM_00332356
SDNY_GM_00332436
Scans of FBI Evidence
SDNY_GM_00332437
SDNY_GM_00332863
Scans of FBI Evidence
Confidential
SDNY_GM_00332864
SDNY_GM_00332869
Scans of FBI Evidence
Highly Confidential
SDNY_GM_00332871
Video from Florida
Highly Confidential
Investigation
SDNY_GM_00332872
SDNY_GM_00332887
Videos from Florida
Confidential
Investigation
SDNY_GM_00332888
SDNY_GM_00332890
SDFL Materials
Confidential
SDNY_GM_00332891
SDNY_GM_00332891
SDFL Materials
Highly Confidential
SDNY_GM_00332892
SDNY_GM_00332894
FBI Florida Documents
SDNY_GM_00332895
SDNY_GM_00332928
FBI FL Documents (included
Confidential
with 328073-328092)
SDNY_GM_00332943
SDNY_GM_00332958
3-D Blueprints, in PBPD
Materials (included with
328462-328667)
SDNY_GM_00356148
FBI FL Documents from Discs
Confidential and
Highly Confidential
Additionally, as you are aware, the Government has seized and extracted data from
multiple electronic devices in connection with search warrants executed at Jeffrey Epstein's
properties in New York and the Virgin Islands. The data from those devices has been subject to a
privilege review, based on privileges asserted by Jeffrey Epstein's estate. Because the estate has
not waived any of those privileges, the Prosecution Team in this case will not have access to any
materials from those devices identified as privileged by the taint review team, and the Government
will not produce any such privileged material to the defense in this case.
Further, it is the Government's current understanding that none of the seized devices
belonged to the defendant, Ghislaine Maxwell, and as a result, it is the Government's
understanding that the Prosecution Team is not legally permitted to provide you with the full set
of non-privileged materials that were extracted from the devices. Instead, the Government
anticipates producing only the materials designated responsive to the relevant warrants authorizing
the search of these devices. Correspondingly, upon completion of the responsiveness review, the
Prosecution Team will only have access to that same set of non-privileged materials deemed
responsive to the relevant warrants. The Government expects to produce these responsive, non-
privileged materials to you by the November 9, 2020 deadline for completion of discovery.
06.20.2018
EFTA00027073

=== Page 3 ===
Page 3
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 or if you wish to arrange a time to
review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
06.20.2018
EFTA00027074


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re:
)
- Epstein
Date: Mon, 08 Jul 2019 03:08:55 +0000
Sounds good. I'll call you then.
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 10:19 PM,
)
wrote:
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:
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
)
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,
Sent from my iPhone
EFTA00026632

=== Page 2 ===
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may
be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before
you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check
in tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being
in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
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,
EFTA00026633

=== Page 3 ===
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00026634


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: GM - MLAT Request to the UK
Date: Mon, 02 Aug 2021 15:11:28 +0000
Attachments: 2021.08.01_MLAT_to_UK_v1.docx
Attached for your review is a draft MLAT to the UK, which we are hoping to send along early this week.
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:
EFTA00025080


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=== Page 1 ===
1A30
FD-340 (Rev. 4-11-03)
File Number
31E- mon- 108062 -GJH30
Field Office Acquiring Evidence NY
Serial # of Originating Document
#162 +163
Date Received
5/29/2008
From
(Name of Contributor/Interviewec)
(Address)
(City and State)
By
To Be Returned
Yes
No
Receipt Given
Yes
No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Federal Rules of Criminal Procedure
Yes
No
Federal Taxpayer Information (FTI)
Yes
No
Title:
Reference:
(Communication Enclosing Material)
Description:
Original notes re interview of
Original GSS serred on
EFTA00024270

=== Page 2 ===
31E - MM. - 108062-GS-1A30
EFTA00024271

=== Page 3 ===
AO110 (Rev. 04/07) Subpoena to Testify Before Grand Jury
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
TO:
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
FGJ 07-103 (WPB) -Tues./No. OLY-85
SUBPOENA FOR:
PERSON
DOCUMENT(S) OR OBJECT(S)
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
Court at the place, date, and time specified below.
PLACE
COURTROOM
Grand Jury Room
United States District Court
701 Clematis Street
DATE AND TIME
West Palm Beach, Florida 33401
6/3/2008 10:30 am
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):*
c.
U.S.
COURTS
Please see additional information on reverse
This subpoena shall remain in effect until you are granted leavelo depart by the court or by an officer acting on
behalf of the court.
CLERK Streen STATEMENT DISTRICT OF
(By) Deputy Clerk
NAME ADDRESS AND PHONE NUMBER OF ASSISTANT U.S. ATTORNEY
This subpoena is issued on application
of the United States of America
500 South Australian Avenue, Suite 400
West Palm Beach, Florida 33401-6235
Tel: (561) 820-8711, ext
. If not applicable, enter "none".
EFTA00024272

=== Page 4 ===
AO110 (Rev. 04/07) Subpoena to Testify Before Grand Jury
RETURN OF SERVICE (1)
DATE
PLACE
RECEIVED
BY SERVER
5/27/08
PLACE
New York, New York
SERVED
collection:
5/29/08
SERVED ON (PRINT NAME)
SERVED BY (PRINT NAME)
TITLE
Special Agent FBI
STATEMENT OF SERVICE FEES
TRAVEL
SERVICES
TOTAL
0.00
DECLARATION OF SERVER (2)
I declare under penalty of perjury under the laws of the
on
contained in the Proof of Service is true and correct.
Executed on
5/30/2008
DATE
corrective:
5/29/08/
ADDRESS
New OF SERVER york, , NY
ADDITIONAL INFORMATION
It should be noted subpoona was
served on 5/29/08 (thursday). SA
made 2 mistake in writing
the date and corrected and initialed each
correction on this sub poena,
(I)
As to who may serve a subpoena and the manner of its service see Rule 17(d), Federal Rules of Criminal Procedure, or Rule 45(b), Federal Rules of Civil
Procedure.
(2)
"Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof
(Rule 45(b), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent parties and criminal
defendants who are unable to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedure)".
EFTA00024273

=== Page 5 ===
U.S. DEPARTMENT OF JUSTICE
INSTRUCTIONS FOR FACT WITNESSES APPEARING ON
BEHALF OF THE UNITED STATES GOVERNMENT
(Not Applicable to Federal Employees)
ENT
OF
FOR TRAVEL ARRANGEMENTS (AIR FARE and/or HOTEL) CALL OMEGA
DEPA
WORLD TRAVEL AT 1-800-411-9287. Identify yourself as a U.S. Attorney's Office
106
witness.
FROM
JUSTITIA
EMERGENCIES ONLY: Before 8:00 am. or AFTER 8:00 p.m. EST CALL 1-800-685-
6342.
READ THE INFORMATION CONTAINED ON THIS FORM BEFORE YOUR COURT APPEARANCE. PLEASE CALL THE
INDIVIDUAL LISTED BELOW IF YOU HAVE QUESTIONS REGARDING TRAVEL AND SPECIFIC ENTITLEMENTS. IF YOU
HAVE A MEDICAL CONDITION OR FAMILY SITUATION THAT REQUIRES SPECIAL CONSIDERATION, PLEASE ADVISE
THE INDIVIDUAL LISTED BELOW AS SOON AS POSSIBLE.
CONTACT PERSON(s):
TELEPHONE NUMBER:
-VERIFY YOUR ATTENDANCE
On the last business day BEFORE you travel to testify, call Special Agent
with FBI, at
0 verify your exact
attendance date.
~ APPEARANCE IN ANOTHER CITY -
If you are required to travel to another city to appear in court, please contact Omega World Travel at 1-800-411-9287 to make your travel
arrangements. Any amount advanced to you will be deducted from your fees and allowances.
REIMBURSEMENT OF EXPENSES AND ATTENDANCE FEES-
A.
ATTENDANCE FEE: You will be paid a fee of $40.00 per day, including travel days.
B.
TRANSPORTATION: Call Omega World Travel at 1-800-411-9287 to arrange for your transportation. Reimbursement will
be made for travel by the least expensive method reasonably available to you (i.e., traveling by privately owned vehicle vs. cost
of airfare). The following rules apply to transportation expenses:
1.
Local Travel: The recommended method of travel in the local area of courts is transit bus/subway.
2.
Privately Owned Vehicles (POV): You will be reimbursed the following amounts:
Motorcycle: $0.305 per mile
Automobile: $0.505 per mile
Private Airplane: $1.07 per mile
In addition to the above mileage allowance, necessary tolls, parking and other fees may be reimbursed. If two or more witnesses travel
in the same vehicle, only one reimbursement for mileage can be made.
IF POV EXPENSES, INCLUDING MILEAGE, TOLLS PARKING AND OTHER ASSOCIATED COSTS, ARE GREATER
THAN THE GOVERNMENT AIRFARE, YOU WILL BE RESPONSIBLE FOR THE DIFFERENCE.
3.
Common Carrier: If you are located outside the local court area, call Omega World Travel listed above for your travel
arrangements. Train or bus will be reimbursed at the government rate. Reimbursement WILL NOT be made for First
Class accommodations, "Frequent Flyer" tickets, or charter service. DO NOT purchase non-refundable tickets. If your
appearance date changes or is canceled, you WILL NOT be reimbursed for non-refundable tickets. If you have any
questions concerning transportation arrangements, please contact the individual(s) listed above.
C.
MEALS: If it is necessary for you to remain away from home overnight, you will receive the following daily meal allowances:
$32.00 for each travel day
PLUS $64.00 for each full day at court
D.
LODGING: If it is necessary for you to remain away from home overnight, you will need to contact Omega World Travel to
make your hotel arrangements. This office will be billed directly, and it will not be an out-of-pocket expense for you. (The
allowable government rate for hotel during this period will be $ 103.00.)
ALL CLAIMS FOR PARKING AND TOLLS MUST BE SUPPORTED BY A RECEIPT, OTHER EXPENSES TO $25.00 OR
MORE MUST BE SUPPORTED BY A RECEIPT, WITH THE EXCEPTION OF MEALS AND MILEAGE.
DISMISSAL-
When you are advised that you have completed your testimony and your attendance is no longer required, you should request information
regarding the payment of the fees and allowances outlined above. The individual requiring your attendance will provide you with a Fact
Witness Voucher. You will be required to list your expenses on this voucher. The Voucher will be submitted to the U.S. Marshal's Service
for payment. The U.S. Marshals Service will process the voucher and MAIL the payment to you. If you require funds to return home,
you must bring this fact to the attention of the individual requiring your attendance, who will notify the U.S. Marshal's Service.
Form OBD-2
MARCH 2006
EFTA00024274


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: zip is 03221
Date: Wed, 01 Jul 2020 21:40:35 +0000
On 4/14/2016, three checks ($3,609,665.75, $9,031,636.31 and $1,561,387.91) totaling $14,202,689.97 were deposited
into the UBS account titled 116 East 65th Street LLC (Y1 23962). UBS documents reflect that Ghislaine Maxwell is the
owner of that account. On 4/20/16, $14,194,596.46 was transferred from UBS 116 East 65th Street account to the UBS
account titled Ghislaine Maxwell (Y1 23575).
In November of 2016, the amount of $14,250,000 was transferred from Maxwell accounts to the Angara Trust account at
UBS.
From:
Sent: Wednesday, July 01, 2020 17:34
To:
Cc:
Subject: zip is 03221
Assistant U.S. Attorney
Southern District of New York
EFTA00026525


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
)"
)"
(USANYS)"
Cc:
)"
)"
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 03 Mar 2020 17:26:33 +0000
I will do everything in my power to make that happen.
On Mar 3, 2020 12:25 PM, "
)"
wrote:
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
On Mar 2, 2020 11:15 AM,
"
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
)
is
(USANYS)
is
EFTA00024749

=== Page 2 ===
is
(USANYS)
Cc:
in
i
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
V.
(USANYS)
Cc:
>;
is
i
is
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
EFTA00024750

=== Page 3 ===
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info - -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
EFTA00024751

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Southern District of New York
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=== Page 1 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 1 of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
Case No. 19 Civ. 10788
Plaintiff,
COMPLAINT
-against-
AND JURY DEMAND
DARREN K. INDYKE and RICHARD D. KAHN,
as EXECUTORS OF THE ESTATE OF JEFFREY E.
EPSTEIN,
Defendants.
X
Plaintiff
,
by and through her attorneys, Cuti Hecker Wang LLP and
Allred, Maroko & Goldberg, for her Complaint alleges as follows:
NATURE OF THE ACTION
1.
When Plaintiff
was just seventeen years old, living on her
own and working full-time to support herself, Jeffrey Epstein preyed open her, manipulated her
to be completely dependent on him, and sexually abused her.
2.
Epstein was presented to
as someone who had learned about her
challenging circumstances and had the resources and interest to assist her - including by helping
her to attend college and study abroad to see the world.
was introduced to Epstein by her
sister, but
was unaware that Epstein had been manipulating and sexually abusing her sister,
as Epstein's total power and control over
sister made it impossible for her to say
anything about it.
3.
During their early interactions, Epstein led
to believe that he would
help her achieve her dream of becoming a translator, and he arranged for
to study abroad
in Spain.
gave up her job and her apartment in anticipation of this life-changing
opportunity, leaving her completely dependent on Epstein and his continuing generosity.
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=== Page 2 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 2 of 13
4.
Epstein exploited this power over seventeen-year-old
to sexually
abuse her repeatedly. Ultimately, he raped and sexually assaulted her frequently and in a variety
of places and settings, including by trafficking
to his homes in New York, New Mexico,
Florida, the Virgin Islands, and France. He treated her like an object for his sexual gratification.
5.
These assaults caused
to feel completely intimidated and fearful.
She froze up and began to cry, able to think only about trying to survive.
6.
Epstein continued to exert total control over
life for two more
years, trafficking her around the country and the world and sexually abusing her on a frequent
basis. During this time,
felt deep despair and isolation, and developed a severe and self-
destructive eating disorder. Still within his power and control,
confided in Epstein about
her disorder, mistakenly believing that she could trust him. Rather than help her, Epstein cast
her out within hours of her admission, sending her back to a place where she no longer had a
home, a job or any resources or support.
7.
Epstein's abuse destroyed
life. She sank into alcoholism and
other self-harm, unable to trust others but not understanding why.
8.
At the same time, like so many childhood sex abuse victims, she did not
comprehend how it had undone her or her life, or how it impacted her.
9.
Now a working mother of three,
is still just beginning to
understand the depth of the injuries from the sexual assaults that Epstein inflicted on her
beginning when she was seventeen. She feels the toll of Epstein's abuse every day. She feels
dysfunctional, on-edge, overwhelmed, and like she is on the verge of a psychological
breakdown. She has difficulty sleeping and often has flashbacks to Epstein's abuse.
10.
Epstein died in August 2019, before
or the countless other
girls he preyed upon could obtain a modicum of justice.
2
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=== Page 3 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 3 of 13
11.
brings this action seeking, at last, some remedy for the
egregious abuse that Epstein inflicted when she was a child.
PARTIES
12.
Plaintiff
is an individual who resides in Arizona.
13.
Defendants Darren K. Indyke and Richard D. Kahn are the Executors of
the Estate of Jeffrey E. Epstein (the "Estate"). As Executors of the Estate, Defendants are liable
for the acts and omissions of Epstein and his agents. For purposes of 28 U.S.C. $ 1332,
Defendants Indyke and Kahn are deemed to be citizens of the United States Virgin Islands,
where Epstein was domiciled at the time of his death.
JURISDICTION AND VENUE
14.
This Court has subject-matter jurisdiction pursuant to 28 U.S.C. $ 1332
because this case is between citizens of different states and the amount in controversy exceeds
$75,000.
15.
Venue is proper in this District pursuant to 28 U.S.C. $ 1391(b)(2)
because a substantial part of the events or omissions giving rise to the claim occurred in this
District.
16.
This Court has personal jurisdiction over Defendants. As Executors of the
Estate, Defendants Indyke and Kahn are subject to personal jurisdiction in this Court because
Epstein was subject to personal jurisdiction at the time of his death.
17.
This Court had both specific and general personal jurisdiction over Epstein
at the time of his death.
18.
Epstein resided in New York State a substantial portion of the time during
the time period at issue in this lawsuit, and through the time of his death.
3
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=== Page 4 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 4 of 13
19.
Epstein resided in the Metropolitan Correctional Center in New York
County at the time of his death.
20.
Epstein conducted substantial business operations in New York.
21.
Epstein owned and/or controlled numerous companies with principal
places of business in New York.
22.
Epstein owned substantial real property assets in New York, including the
townhouse located at 9 East 71st Street in Manhattan, which is valued at $55 million or more.
23.
New York was the epicenter of Epstein's criminal sex-trafficking
enterprise. For years, Epstein and his agents took actions in New York in order to arrange for
minor girls to be trafficked to his homes throughout the country in order to perform sexual acts
for him. Epstein's trafficking and abuse of
was part of that New York-based
criminal enterprise.
24.
From his Manhattan townhouse, Epstein directed a vast network of agents
in recruiting minor girls to be brought to him for his sexual use.
25.
Epstein sexually abused many minor girls, including
in his
,
Manhattan townhouse.
26.
On many occasions, Epstein and his agents made phone calls from New
York to schedule appointments for minor girls to come to Epstein's residences outside of New
York in order to perform commercial sexual acts for Epstein.
27.
Upon information and belief, Epstein and/or his agents were present in
New York when they took various actions to facilitate the trafficking of
for the
purpose of performing sexual acts for Epstein.
JURY DEMAND
28.
Plaintiff hereby demands a trial by jury on all of her claims in this action.
4
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=== Page 5 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 5 of 13
FACTUAL ALLEGATIONS
29.
When Plaintiff
was seventeen years old, Jeffrey Epstein
preyed upon her, manipulating her to be completely dependent on him and then sexually
assaulting and raping her on numerous occasions. Epstein continued this pattern of manipulation
and frequent sexual assault for years, leaving
with deep emotional wounds that she is
still just beginning to grapple with.
30.
By age seventeen,
had already lived through tremendously
challenging circumstances. At eleven years old, she was homeless for a year, staying with
various friends and seeing her mother only about once a week. At fifteen,
began working
in order to support herself. At sixteen,
living situation was again unstable, and she
moved to Los Angeles to live with her older sister.
31.
initially tried to go to school in Los Angeles, but was unable to
continue due to the need to work full-time to support herself.
lived with her sister and
worked at a hair salon, eventually getting her GED. By the time
met Epstein, she had
already been living on her own and working full-time for a year-and-a-half.
32.
sister - who is five years older than her - had previously met
Epstein and traveled with him.
sister described Epstein to her as a generous wealthy
person, and reported that he often helped make it possible for people to attend college.
sister reported that Epstein had heard
story and that he wanted to help.
33.
Unbeknownst to
Epstein had been manipulating and sexually
abusing her sister.
had no idea that her sister had been involved in any type of sexual
interactions with Epstein. Epstein's power and control of
sister made it impossible for
her to say anything.
5
EFTA00025113

=== Page 6 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 6 of 13
34.
met Epstein for the first time in 2002, when she was seventeen years
old. Epstein was visiting Los Angeles, and
drove with her sister to meet him at the Hotel
Bel-Air.
35.
During that first meeting, Epstein lay on a bed in his spacious hotel suite,
fully clothed. He asked
sister to massage his feet, then encouraged
to join her.
Afterwards, Epstein took them shopping, and insisted on buying several items for
36.
After that meeting, Epstein kept in touch with
through frequent
phone calls. Epstein veered the conversation toward
career goals and how Epstein could
help her achieve them. He purported to want to help her and guide her to a better life.
37.
Epstein offered to send
to school to learn hairdressing, but
made clear that this was not what she wanted to do in the long term.
explained that she
had a passion for languages and for people, and that her dream was to be a translator.
38.
Epstein claimed that he wanted to help
study to become a translator.
He suggested that he would pay for
to study in Spain for a semester. Soon after, Epstein
helped her to obtain a letter of recommendation from her high school counselor and helped her
get accepted to study at the University of Madrid.
39.
was over the moon, feeling her dreams were coming true. Epstein
made sure she felt that it was all his doing.
40.
prepared for this exciting opportunity to study abroad and pursue
her dream career. She gave notice at her hairdressing job and gave up her apartment in Los
Angeles, preparing to move to Spain.
41.
Before
left for her school program, however, Epstein began what
would become a long pattern of using her as his sexual object.
6
EFTA00025114

=== Page 7 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 7 of 13
42.
In approximately the summer of 2002, Epstein flew
and her sister to
his ranch in New Mexico.
felt no reason to be wary of Epstein. He had been kind in their
first meeting and had acted with generosity towards her.
43.
When
got to Epstein's ranch, Epstein's close associates Ghislaine
Maxwell and
were there. Maxwell asked
questions about herself and took
her horseback riding.
invited
to go swimming.
44.
After
swam, Epstein asked her to go into a massage room along with
began massaging Epstein, and
innocently joined in, as she had when her
sister massaged Epstein's feet the first time.
45.
At that point, Epstein began fondling
and took off
shirt.
became very uncomfortable, as the massage had quickly and unexpectedly turned into a
sexual encounter. Epstein reached inside
bathing suit and fondled her genitals.
began crying, but Epstein continued to grope her as he masturbated to completion.
46.
felt extremely vulnerable. Epstein had arranged the circumstances
to ensure that
was completely at his mercy.
had given up her job and her apartment
in order to travel to Spain at Epstein's expense. If Epstein decided to rethink his generosity at
any point,
would have had nothing, and would have been left homeless and jobless once
again, after being brought so close to her dream. Even though Epstein had preyed upon her and
sexually assaulted her,
understood she had no choice but to submit to him. His power over
her was all-encompassing.
47.
Epstein viciously exploited this power dynamic. In the summer and fall of
2002, he flew seventeen-year-old
to his homes in New York, Florida, and the U.S. Virgin
Islands, sexually assaulting her in each of those locations.
48.
In or around December 2002, Epstein flew
to stay at his townhouse
7
EFTA00025115

=== Page 8 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 8 of 13
located at 9 East 71st Street in Manhattan. While they were in the dining room of the townhouse,
Epstein without warning stuck his hand down
pants and fondled her genitals. It was as if
she were his toy.
49.
In or around that same month, at Epstein's home in Florida, Epstein crept
into
bedroom while she was sleeping and raped her.
50.
Also around that same month, at the private island Epstein owned in the
Virgin Islands, Epstein ordered
to massage him, then proceeded to sexually assault her in
the massage room.
51.
finally traveled to Spain to study in or around the end of 2002.
52.
In early 2003, when
was still seventeen years old, Epstein flew her
from Madrid to Paris. At his home in Paris, Epstein again crept into
bedroom while she
slept and raped her.
53.
When Epstein inflicted these sexual assaults on
,
she felt completely
intimidated and fearful. All she could think about was trying to survive. Her body froze up, and
she began crying.
54.
After
semester in Madrid, she had no home and no job. Instead,
Epstein brought her to live a nomadic lifestyle in his close orbit.
traveled around the
country with Epstein and his entourage, which generally included Maxwell,
, and others.
Virtually every few days, Epstein would bring
to a different home of his, including his
Manhattan townhouse and throughout the country, where he continued to sexually assault her on
a frequent basis. Epstein regularly used his private planes to traffic
into various locations
for his sexual abuse of her.
55.
Epstein had power over every aspect of
life, and he had groomed
to be completely dependent on him and completely submissive to him. Epstein treated
8
EFTA00025116

=== Page 9 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 9 of 13
as a sexual object, using her body for his sexual gratification frequently and at his whim.
56.
Eventually, by approximately 2004, Epstein arranged for
to live in
an apartment at 301 East 66th Street in Manhattan, just blocks from his townhouse, when she
was in New York.
57.
This pattern - of Epstein exercising total control over
life and
using her as a sexual object whenever he desired - continued throughout 2003 and 2004. Epstein
arranged for
to study abroad two more times, apparently when he grew bored with having
her around. Each time,
lived in this nomadic orbit with Epstein both before and after
traveling to attend school.
58.
Epstein also tried to introduce
to his "friends" and essentially offer
her as a sexual object to them. In one instance, Epstein had
spend time with a well-known
Hollywood producer, who then demanded and attempted to engage in abusive sexual behavior.
barely escaped.
59.
By 2004,
felt deep despair and isolation. There was no one she
could talk to about what Epstein was doing to her. Instead, Epstein had ensured that she thought
he was the only person in her life whom she could trust.
60.
developed a severe eating disorder, for the first time, in or around
2004. After she had struggled with the disorder for six months or a year, it became too much to
bear. She confided in Epstein about the eating disorder, still manipulated into thinking he was
someone she could trust.
61.
Instead, from the moment Epstein learned of
self-destructive
behavior, he immediately cast her out. Literally within hours of
anxiously confessing to
Epstein that she did not know why, but had a compulsive need to binge and purge, he threw her
out. He instructed her to pack up her belongings and arranged for her to be flown to Arizona.
9
EFTA00025117

=== Page 10 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 10 of 13
62.
But there was nothing left for her in Arizona. She still had no idea what
had happened to her and felt it was all her fault.
63.
Epstein's abuse destroyed
life. After being cast out by him after
two years of a lavish, if abusive, lifestyle, she sank into alcoholism and other self-harm, unable
to trust others but not understanding why.
64.
is now a working mother raising three children. She is still
struggling to put her life back together.
65.
is still in the nascent stages of understanding the deep and
lasting injuries that Epstein's pattern of abuse has caused her, but she feels the effects every day.
She feels dysfunctional, on-edge, and constantly overwhelmed. She has difficulty sleeping. She
often has flashbacks to Epstein's sexual assaults. She feels like she is on the verge of a
psychological breakdown.
66.
This action is timely under the law of each jurisdiction whose law might
be determined to govern
claims or aspects thereof, including without limitation
New York, New Mexico, Florida, and the Virgin Islands.
67.
still has not disclosed her abuse to a licensed medical or
mental health care provider in the context of receiving health care from the provider.
68.
is still just beginning to process and understand the full extent
of the injuries that Epstein's abuse had caused her and the connection between Epstein's abuse
and the emotional and psychological injuries she had experienced.
69.
This action is timely under New York law because it falls within New
York CPLR 214-g and is brought during the one-year time period set forth in that section. The
claims brought herein allege intentional and negligent acts and/or omissions for physical,
psychological, and other injury suffered as a result of conduct that would constitute sexual
10
EFTA00025118

=== Page 11 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 11 of 13
offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions
were committed against
when she was less than eighteen years of age.
70.
Epstein's conduct constitutes "childhood sexual abuse" within the
meaning of New Mexico Stat. $ 37-1-30 and "abuse" within the meaning of Florida Stat. $
95.11(7).
FIRST CAUSE OF ACTION
(Battery)
71.
Plaintiff hereby incorporates each of the foregoing paragraphs as if fully
set forth herein.
72.
In committing the acts described above, Epstein intentionally subjected
Plaintiff to bodily contact that was offensive in nature.
73.
Epstein intentionally touched Plaintiff in a rude, insolent, or angry
manner.
74.
As a result of Epstein's actions, Plaintiff suffered damages in an amount to
be determined at trial.
SECOND CAUSE OF ACTION
(Assault)
75.
Plaintiff hereby incorporates each of the foregoing paragraphs as if fully
set forth herein.
76.
In committing the acts described above, Epstein engaged in physical
conduct that placed Plaintiff in imminent apprehension that he would harm her.
77.
As a result of Epstein's actions, Plaintiff suffered damages in an amount to
be determined at trial.
11
EFTA00025119

=== Page 12 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 12 of 13
THIRD CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
78.
Plaintiff hereby incorporates each of the foregoing paragraphs as if fully
set forth herein.
79.
In committing the acts described above, Epstein engaged in extreme and
outrageous conduct.
80.
In doing so, Epstein acted with the intent to cause and/or disregard of a
substantial likelihood of causing Plaintiff to suffer severe emotional distress.
81.
As a direct result of Epstein's actions, Plaintiff suffered severe emotional
distress.
82.
As a result of Epstein's actions, Plaintiff suffered damages in an amount to
be determined at trial.
WHEREFORE, Plaintiff respectfully requests that judgment be entered against
Defendants as follows:
a. Awarding compensatory damages for all physical injuries, emotional distress,
psychological harm, anxiety, humiliation, physical and emotional pain and
suffering, family and social disruption, and other harm, in an amount to be
determined at trial;
b. Awarding punitive damages in an amount to be determined at trial;
c. Awarding attorneys' fees and costs pursuant to any applicable statute or law;
d. Awarding pre- and post-judgment interest on all such damages, fees and/or costs;
e. Attaching all of Defendants' real property and other assets located in the State of
New York pursuant to New York CPLR 6201 et seq. and Federal Rule of Civil
Procedure 64; and
f.
Awarding such other and further relief as this Court may deem just and proper.
12
EFTA00025120

=== Page 13 ===
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 13 of 13
Dated: New York, New York
November 21, 2019
CUTI HECKER WANG LLP
By: /s/ Mariann Meier Wang
Mariann Meier Wang
Daniel Mullkoff
305 Broadway, Suite 607
New York, New York 10007
(212) 620-2603
mwang@chwllp.com
ALLRED, MAROKO & GOLDBERG
Gloria Allred
305 Broadway, Suite 607
New York, New York 10007
(212) 202-2966
Attorneys for Plaintiff
13
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From:
)"
To:
)"
Subject: RE: Discovery questions
Date: Thu, 20 Aug 2020 22:27:15 +0000
Got it, thanks!
Duplicate
EFTA00023666

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Duplicate

=== Page 3 ===
Duplicate

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Duplicate

=== Page 5 ===
Duplicate

=== Page 6 ===
Duplicate

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=== Page 1 ===
From:
To:
Cc:
Subject: updated protective order
Date: Tue, 23 Jul 2019 00:49:17 +0000
Attachments: 2019-07-22,_JE,_protective_order_for_discovery_]
).docx
On the one hand, I've now expended any goodwill previously earned with
by messing with the formatting and
breaking this all out into individual paragraphs; on the other, she has signed off, with edits incorporated in the attached.
let me know if any thoughts and I'll pass it up the chain. Thx.
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein update
Date: Sat, 10 Aug 2019 16:36:40 +0000
In addition to
can you please include Chief
Thank you
From:
Sent: Saturday, August 10, 2019 12:32 PM
To:
Cc:
Subject: Re: Epstein update
Hi all,
Who is his lead counsel? The Warden is preparing the formal letter for the Court, in which your office, the USMS, USPO, and
lead counsel are cc'ed. Do you have an email address for him/her?
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
>>>
8/10/2019 11:30 AM >>>
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic information so that we
can relay it to his attorneys who can relay it to his family. When can we expect to get either some sort of statement we can
pass along to counsel as accurate and reliable or have a call with someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP, and given the
BOP press release that was just put out I assume we need to speak with someone there. Please advise.
Thank you.
EFTA00024354

=== Page 2 ===
On Aug 10, 2019, at 10:43,
> wrote:
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be seeing
information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know as soon as possible
the very basic facts, such as time and cause of death at the absolute minimum. It has now been hours since this was
reported publicly. Please advise when we can expect to receive either a written report on those basic facts or when we can
have a call to get that information to relay to his counsel. It is extraordinarily frustrating to have to tell them that we have
less information than the press. Please advise.
Thank you,
On Aug 10, 2019, at 08:46,
wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
Cc:
in
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
> wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
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
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From:
"
(USANYS)"
To:
)"
)"
Bcc: "USAHUB-USAJournal111"
Subject: Response to Rule 16/Brady Letter
Date: Mon, 19 Oct 2020 22:49:40 +0000
Embedded: Response_to_Rule_16_Brady_Letter.msg
Sender:
Subject: Response to Rule 16/Brady Letter
Message-Id:
<SN5P110MB0336A334E131308BF6F70A1E8A1E0@SN5P110MB0336.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
EFTA00024735


c1: EFTA00025175
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025175.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
,
(USANYS)"
Subject: NPA letter
Date: Thu, 22 Apr 2021 20:57:00 +0000
Attachments: 2021-04-22_Govt_Letter_Regarding_NPA.docx
Can you take a quick look and let me know if there are any large issues to discuss? Otherwise I'll circulate it more broadly
to
and everyone can do a very close line read thereafter. Would like this to go to them by 530 if possible.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00025175


c1: EFTA00026716
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026716.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
)"
,
Cc:
(
)"
Subject: Message pad scans
Date: Wed, 12 Jun 2019 21:52:47 +0000
Attachments: MP_scan_guest_house_office_desk.pdf;MP_scan_item_2_book_1.pdf;
MP_scan_item_2_book_2.pdf_MP_scan_iten_2_book_3.pdf; MP_scan_tem_16.pdf;
MP_scan_item_17.pdf; MP_scan_kitchen.pdf
Hey all,
Attached are the message pad scans. Let me know if you have questions.
Thanks,
Special Agent
FBI New York
VCAC/Human Trafficking
C:
O:
EFTA00026716


c1: EFTA00024850
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024850.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B6
Evidence
31E-MM-108062 -- 1B6
Item:
Evidence
General
Type:
(U//FOUO) Box containing 1) MEDICAL SUPPLIES PBPD 05-386(1) 2) 727 LETTERHEAD (2) 3) INVOICE
#42700 (3) 4) AMAZON.COM A.M. (4) 5) WHITE PAPER J.L. (5) 6) MESSAGE FROM J. (6) 7) MESSAGE FROM
J.L. (7) 8) WHITE PAPER 2#S (8) 9) WHITE PAPER (917) (9) 10) MISC. DOCUMENTS - TRASH PULL PBPD 05-
874(1) 11) MISC. PAPERWORK- TRASH PULL PBPD 05-878(1) 12) TWO MAGAZINES - TRASH PULL PBPD
05-901(1) 13) PAPER WITH A.S.- TRASH PULL PBPD 05-915(1) 14) VHS T-160 CASSETTE PBPD 05-929(1)
Description: 15) SONY MICRO CASSETTE (2) 16) SONY MICRO CASSETTE (3) 17) SONY MICRO CASSETTE (4) 18)
SONY MICRO CASSETTE PBPD 05-937(1) 19) SONY MICRO CASSETTE (2) 20) SONY MICRO CASSETTE (3)
21) SONY MICRO CASSETTE (4) 22) MISC PAPERWORK- TRASH PULL PBPD 05-941(1) 23) SONY MICRO
CASSETTE PBPD 05-942(1) 24) SONY MICRO CASSETTE (2) 25) MISC PAPERS - TRASH PULL PBPD 05-
943(1) 26) CLEAR PIECE OF PLASTIC PBPD 05-944(1) 27) MISC PIECES OF PAPER - TRASH PULL (2) 28)
SONY MICRO CASSETTE PBPD 05-945(1) 29) SONY MICRO CASSETTE (2)
Location:
E03707388 - ECR8
Barcode:
E4229233
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY. NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: No
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/2
EFTA00024850

=== Page 2 ===
7/20/2021
FD-1087
Collected From: (U//FOUO) DET
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
Receipt Given:
No
Holding Office:
MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
2/2
EFTA00024851

=== Page 3 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B6
Barcode : E4229233
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 16:00am
Accepted By:
Printed Name:
Signature: &
Reason: STORAGE.
Date/Time: 2-8-08 330PM.
Accepted By:
Printed Name:
BAYARDO L. RAMOS
RELEASED TO SA.
Signature: tea-
Reason:
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 fall IBS
Date/Time: 01/13/2009 3:14Pm
Accepted By:
Printed Name:
Signature: 2800
Reason: STORAGE.
Date/Time: 01-13-09
3:15PM
Accepted By:
Printed Name:
Signature:
Reason:
Printed Name:
Rx
Date/Time:
Accepted By:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
6/14/19
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name
:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
EFTA00024852

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody
Date and
Feder:4783-4467-6408
Accepted Custody
Date and
Time
Signature: More
Time
Signature:
6/17/19
c/8/19
Printed Name/Agency
FBI
9:35AM
Printed Name/Agency:
Reason:
2:34
Relinquished Custody
Reason: Transferred ell to NY
Date and
Accepted Custody
Date and
Time
Time
Signature:
6/18/19
Signature:
6/18/19
Printed Name/Agency:
Printed Name/Agency:
Reason:
CCO
3:45P
Reason: Evidence kevin
3:45p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
3/15/21
Signature:
3/15/21
Printed Name/Agency:
FBI
Printed Name/Agency:
Reason: Storage
4:30p
Reason: Charged in
4:30pm
Date and
Printed Signature: Relinquished Name/Agency: Hall Road Custody
Accepted Custody
Date and
Time
Time
3/3/121
Signature:
3/31/21
Printed Name
Reason:
C/O
335r
Reason:
Review
335p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
4/8/21
Signature:
Printed Name/Agency
21/8/21
Printed Name/Agency:
Reason: Storage
2:33P
Reason:
Chargedin
3:33pm
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: 6
Barcode: E4229233
This form is incomplete without reference to the FD-1087.
EFTA00024853


c1: EFTA00024422
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024422.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Moyne, Parvin"
To:
)"
Cc: "Moyer, Thomas"
)"
Subject: Re: 2019.8.15 - SDNY Production Index.xlsx
Date: Thu, 22 Aug 2019 00:01:02 +0000
Either works for us so please choose what is most convenient for you.
Best,
Parvin
On Aug 21, 2019, at 6:45 PM,
)
wrote:
Parvin,
Not a problem. We could do any time after noon on that Tuesday (the 10th) or any time on the Thursday (the 12th).
Would either of those work?
thanks,
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 09:25
To:
Cc: Moyer, Thomas
is
i
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
I'm so sorry for the inconvenience but those dates are not good on our end.
The following week is relatively clear. Might September 9th work? Or other dates that week?
Best,
Parvin
From:
Sent: Tuesday, August 20, 2019 11:58 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
is
i
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can - is there a time during the afternoon of September 5 or the morning of September 6 that would
EFTA00024422

=== Page 2 ===
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
From: Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
To:
is
)
V.
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a
presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with
Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have
noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we
have provided so you can more readily identify whatever information you are most interested in. Following the proffer,
if there are particular accounts or transactions of interest, we can identify the person within DB who can best answer
questions on those areas and that person would then meet with you.
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)
Best,
Parvin
From:
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin
is
is
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out
scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with
Deutsche Bank personnel, etc? And approximately how long should we be planning to block out?
thanks,
From: Moyne, Parvin
Sent: Monday, August 19, 2019 12:04
To:
is
)
V.
EFTA00024423

=== Page 3 ===
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Hi
-
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most
sense on your ends.
We have time this week (Thursday or Friday afternoon) and next week (Monday - Wednesday), and we have time in
September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.
Best
Parvin
From:
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin
is
in
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
EXTERNAL Email
Parvin,
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think
we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and
trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?
thanks,
From: Moyne, Parvin
Sent: Thursday, August 15, 2019 09:48
To:
is
)
V.
Cc: Moyer, Thomas
Subject: 2019.8.15 - SDNY Production Index.xlsx
&
Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
EFTA00024424

=== Page 4 ===
One Bryant Park
New York, NY 10036-6745
USA
Direct: +1
Internal:
Fax: +1
akingump.com
Bio
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00024425


c1: EFTA00026649
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026649.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
)"
Subject: Accepted: Epstein bail hearing
Date: Wed, 10 Jul 2019 05:50:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00026649


c1: EFTA00026698
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026698.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: 12.2 letter
Date: Mon, 11 Oct 2021 23:25:44 +0000
Attachments: 2021.10.XX_GM_12.2_letter_to_defense.docx
Here's a quick draft of the 12.2 letter we discussed.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00026698


c1: EFTA00023661
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023661.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nicole Simmons
To:
"
111
"
111
i
111
...
Cc: Laura Menninger
Jeff Pagliuca
Ann Lundberg
<CEverdell@CohenGresser.com>,
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Thu, 03 Sep 2020 21:56:32 +0000
Attachments: 2020.09.03_Notice_of_Appeal-Denial_of_Motion_to_Modify_POpdf
Inline-Images: image001.jpg
Dear Counsel:
At the request of Laura A. Menninger, please see attached Ms. Maxwell's Notice of Appeal that has been sent via
Overnight Delivery to the SDNY-Clerk for filing.
Thank you,
Nicole
Nicole Simmons
Haddon, Morgan and
EFTA00023661


c1: EFTA00025513
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025513.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Passport
Date: Thu, 18 Jul 2019 00:54:14 +0000
Adding to this, if you could please bring any personal effects seized at the arrest (money, wallet, whatever) -- not
including the devices we have search warrants for -- we can return that to his lawyers tomorrow. Thanks.
Original Message
From:
Sent: Wednesday, July 17, 2019 20:47
To
Cc:
Subject: Passport
,
Hope you had a good flight back. Could you please bring Epstein's Austrian passport to court tomorrow? His
attorneys have asked to inspect it. Let us know if that causes any issues (with chain of custody, for example) and
we can discuss.
Thanks!
Sent from my iPhone
EFTA00025513


c1: EFTA00026711
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026711.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Thu, 13 Aug 2020 21:06:24 +0000
Thank you so much for handling!!
From:
Sent: Thursday, August 13, 2020 5:06 PM
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
I just sent the next round of discovery via FedEx. The password for this drive is
We also sent a letter with
the password in a separate envelope.
Please let us know when it arrives.
Thank you,
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
EFTA00026711

=== Page 2 ===
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,
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
EFTA00026712


c1: EFTA00024857
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024857.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B8
Evidence
31E-MM-108062 -- 1B8
Item:
Evidence
General
Type:
(U//FOUO) Box containing 1) VHS TAPE OF SURVEILLANCE PBPD 05-1205(1) 2) VHS TAPE OF
SURVEILLANCE (2) 3) VHS TAPE (3) 4) VHS TAPE (4) 5) VHS TAPE (5) 6) VHS TAPE (6) 7) VHS TAPE (7) 8)
SIXTEEN DVD-R DISCS PBSO PBPD 05-1219(1) 9) CINGULAR ENVELOPE WITH SUBPOENA INFO PBPD 05-
Description: 1245(1) 10) CINGULAR WIRELESS CD (2) 11) SONY MICRO CASSETTE PBPD 06-21(1) 12) GREEN FOLDER
A. PBPD 06-24(1) 13) SONY MICRO CASSETTE PBPD 06-39(1) 14) SONY MICRO CASSETTE PBPD 06-59(1)
15) SONY MICRO CASSETTE PBPD 06-95(1) 16) T-160 VIDEO CASSETTE PBPD 06-120(1) 17) SONY MICRO
CASSETTE PBPD 06-182(1) 18) SONY MICRO CASSETTE PBPD 06-348(1) 19) CD PBPD 06-397(1)
Location:
E03707388 - ECR8
Barcode: E4229235
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #: None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
II
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
II
Retention
Retention: No
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
Collected From: (U//FOUO)
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
Receipt Given:
No
Holding Office: MM - - MIAMI
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/2
EFTA00024857

=== Page 2 ===
7/20/2021
FD-1087
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
2/2
EFTA00024858

=== Page 3 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B8
Barcode E429235
Accepted By:
Printed Name:
Signature:
Reason: Collected
Date/Time: 08/28/2006 11:00
Accepted By:
Printed Name:
Reason:
STORAGE
Signature: sla-
Date/Time: 2-8-08 330PM
Accepted By:
Printed Name:
Signature: sta-
Reason:
RELEASED TO SA.
Date/Time: 4-10-08
1100AM.
Accepted By:
Printed Name:
Signature: 2
Reason: Review
Date/Time: 04/10/2008
llialam
Accepted By:
Printed Name:
Signature:
Reason: Return of all I.B.s.
Date/Time 01/13/2009
3:14pm
Accepted By:
Printed Name:
Signature: ged
Reason:
STOLAGE.
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
EFTA00024859

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody Date and
Accepted Custody
Signature: will
Date and
Time
Signature:
Time
6/17/19
Printed Name/Agency
FBI
6/20/19
9:35AM
Printed Name/Agency:
Reason: Transferred to NY
Relinquished Custody
Reason: SUM HOY MIAMI
cm
3:00p
Date and
Accepted Custody
Date and
Time
Signature:
6/29/9
Time
Signature
Printed Name/Agency:
6/24/19
Reason:
llo
Printed Name/Agency:
200 Date and
Reason: Evidence Review
2:10p
Relinquished Custody
Accepted Custody
Date and
Time
Time
Signature:
3/15/21
Signature:
Printed Name/Agency:
FBI
3/15/21
Printed Name/Agency:
Relinquished Custody
Reason: Storage
4:30p
Reason: Charyed
in
4:30pm
Date and
Accepted Custody
Date and
Time
Time
Reason: Printed Signature: Name CTO
3/31/21
Signature
3/31/21
Printed Name/Agency
335.
Reason: Review
335p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Signature:
Time
4/6/21
Signature:
Printed Name/Agency
8:15A
Printed Name/Agency:
4/6/21
Reason: convert 7115
Reason: DUP
8'6
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Signature: Christen may
Time
4/7/21
Signature
Printed Name/Ager
4/7/21
1055
Printed Name/Agency
Reason: RELEASE
Reason: Renew
loss
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
4/8/21
Signature:
Printed Name/Agency:
Printed Name/Agency:
12/8/h
Reason: charge
2:33
Reason:
Relinquished Custody
charges
2:33pm
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: 8
Barcode: E4229235
This form is incomplete without reference to the FD-1087.
EFTA00024860


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026635.pdf
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c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: presentment of Jeffrey Epstein
Date: Mon, 08 Jul 2019 03:11:30 +0000
Importance: Normal
Good evening,
We will formally call this in tomorrow morning, but we wanted to advise you that we expect that defendant Jeffrey
Epstein will be presented tomorrow in United States V. Epstein, 19 Cr. 490. We expect the indictment to be unsealed first
thing tomorrow morning, and we'll get you a copy immediately when that occurs. Mr. Epstein is represented by retained
counsel, including Martin Weinberg
and Reid Weingarten.
We are available anytime tomorrow to provide any useful information in connection with your report, either at the email
addresses here or via phone at the following numbers:
thank you,
EFTA00026635


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00027075.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: [EXTERNAL EMAIL] - RE: Maxwell discovery review
Date: Tue, 20 Oct 2020 01:02:54 +0000
Embedded: RE:_IEXTERNAL_EMAILJ_-_RE_Maxwell_discovery_review.msg
Sender:
Subject: RE: [EXTERNAL EMAIL] - RE: Maxwell discovery review
Message-Id: <7dff2da1-09f4-400e-affb-016ac794b687@FBI.GOV>
Recipient:
EFTA00027075


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023978.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)
[Contractor]"
Subject: Re: Epstein Coconspirators
Date: Wed, 06 May 2020 19:53:20 +0000
Thanks!
Sent from my iPhone
> On May 6, 2020, at 3:45 PM,
(USANYS)
wrote:
>
> Negative
>
>
Sent from my iPhone
V
On May 6, 2020, at 3:43 PM,
(USANYS)
wrote:
ABC News got a tip that something is imminent. We obviously declined, but just for press office edification,
is anything happening?
Sent from my iPhone
EFTA00023978


c1: EFTA00025341
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025341.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
Subject: RE: New York search warrant materials
Date: Mon, 30 Sep 2019 19:26:43 +0000
If you could give me a call, that would be great. At my desk till 4. Thanks!
Senior Forensic Examiner
cell
desk
On Sep 30, 2019 3:16 PM,
)"
wrote:
Perfect, thank you!
if we could please get a list of what CART received, and what's been processed and sent
back, I think that will get us started - and happy to talk via phone if that's easier. Thanks again.
From:
(NY) (FBI)
Sent: Monday, September 30, 2019 15:13
To:
is
)
Cc:
is
)
is
(NY) (FBI)
Subject: New York search warrant materials
Hey
I've copied
here who has handled all of the Epstein evidence that was sent to CART. He should be able to
answer your questions regarding what he's processed.
On Sep 30, 2019 1:57 PM,
)"
wrote:
The taint team here apparently received materials from the search of the New York house but it's way fewer
documents than we would have expected. Can you please let us know exactly how many electronic devices (phones,
computers, hard drives, thumb drives, and/or discs) were sent to CART for processing, and how many were in fact
processed and sent back to us? Or if it's easier to just put us in touch with the CART people directly, that's fine too.
My understanding was that they were processing the materials in the attached, which appears to list approximately
38 computers and/or electronic storage devices seized along with an additional approximately 55 CDs.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00025341


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c0:
=== Page 1 ===
From: "Weinstein, Marc A."
To:
>, , Andrew Tomback
Subject: Epstein NY property
Date: Thu, 16 Jul 2020 14:27:18 +0000
Importance: Normal
Attachments: unnamed
Inline-Images: ATT46538_1.jpg
HHR OnlineMeetingCenter
Dial-In Information (for meetings with no presentations or video)
Dial-In Number:
Conference ID: 612758867
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil
Canada
China
France +
Germany +
India
Ireland
Israel
Japan
Korea (Seoul)
Singapore +
United Kingdom
United States
Full list of dial-in numbers
Meetings with a presentation or video
Connect from computer or mobile device (via network/internet connection)
Help
Try Skype Web App if you are having trouble joining
Joining from a computer using the "Connect from computer or mobile device" link provides additional
capabilities, however you can simply call in from your telephone using the number provided above if your
meeting will not include video or a presentation. Click the "Help" link for additional information if you are a
guest joining a Skype for Business meeting from your computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
EFTA00024501


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=== Page 1 ===
From:
)"
To: "Biase, Nicholas (USANYS)"
Subject: RE: SDNY NEWS CLIPS, OCTOBER 13, 2020
Date: Wed, 14 Oct 2020 02:31:12 +0000
Inline-Images: image001.png
Thanks very much.
From: Biase, Nicholas (USANYS)
Sent: Tuesday, October 13, 2020 11:13 AM
Subject: FW: SDNY NEWS CLIPS, OCTOBER 13, 2020
A few Maxwell/Epstein articles here in case you're interested.
From: Biase, Nicholas (USANYS)
Sent: Tuesday, October 13, 2020 11:03 AM
To: 'Chiefs'
Cc: Margolin, James (USANYS) [Contractor]
Subject: SDNY NEWS CLIPS, OCTOBER 13, 2020
OF
SDNY PRESS CLIPPINGS
DEPARTMENT
JUSTITIA
MAXWELL
NYDN: https://www.nydailynews.com/new-york/ny-jefrey-epstein-maxwell-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszu-story.html
NY POST: https://nypost.com/2020/10/11/new-photos-show-ghislaine-maxwell-at-anti-sex-trafficking-event/
US NEWS: https://www.usnews.com/news/top-news/grticles/2020-10-13/ghislaine-maxwell-to-urge-us-gppeals-court-to-keep-damaging-deposition-secret
MOTHER JONES: https://www.motherjones.com/politics/2020/10/i-called-everyone-in-jefrey-epsteins-little-black-book/
CNN: https://www.cnn.com/2020/10/12/business/leon-block-jeffrey-epstein-opollo/index.html
OK: https://okmagazine.com/exclusives/jeffrey-epstein-withdrew-800k-cash-arrest/
NYT:
https://www.nytimes.com/2020/10/13/books/review/what-tech-cals-thinking-adrian-daub.html
MATTERS OF INTEREST
POLITICO: https://www.politico.com/newsletters/weekly-transportation/2020/10/13/a-tale-of-two-responses-to-pandemic-travel-790929
TELEGRAPH: https://www.telegraph.co.uk/technology/2020/10/12/microsoft-takes-masive-cyber-crime-network-feors-wil-used/
CNN: https://www.cnn.com/2020/10/12/politics/judges-reject-voter-fraud-claims/index.html
BLOOMBERG: https://news.bloombergtax.com/financial-acounting/fraud-and-ineptitude-undermine-covid-relief-opinion
NYT: https://www.nytimes.com/2020/10/12/nyregion/cuomo-coronavirus-orthodox-shutdown.html
BUZZFEED NEWS:https://www.buzzfeednews.com/article/kenbensinger/newyork-owed-money-man-tweeted-trump-ventilators
JD SUPRA: https://www.jdsupra.com/legglnews/rnc-deputy-finance-chair-elliott-broidy-29590/7
THE HILL: https://thehill.com/homenews/house/520712-two-ethics-groups-cal-on-house-to-begin-impeachment-proceedings-against-bar
WAPO: https://www.washingtonpost.com/politics/2020/10/13/democrats-confirmation-hearing-flubs-loom-over-barret-hearing/
BUFNEWhtps:/bufalonews.com/news/locol/inexpicablepensive-ollinsprepgres-forpion-whileblastno-prosecutorsjudge/artice_d80624e0c6-1eb-085-ef62ad25901hml-
BUSINESS INSIDER: https://www.businessinsider.com/exclusive-interview-rick-ggtes-book-mueller-star-witness-2020-10
BREITBART: https://www.breitbart.com/2020-election/2020/10/12/polakjoe-bidens-disastrous-short-list-for-attorney-general-cuono-yate-abrams-bhorara-weisman/
EFTA00025390

=== Page 2 ===
NBC:https://www.nbcrightnow.com/crime/free-humon-traficking-gwarenes-webinar/article_ec374086-0c111eb-803a-fb10c24d21d4.html
BARRON'S: https://www.barrons.com/articles/deutsche-bank-makes-bold-buy-call-on-ford-stock-51602597239
LEXOLOGY: https://www.lexology.com/library/detail.aspx?g=6b349d6e-egfe-43d4-ae3e-33a05f4ffe6d
CNN: https://www.cnn.com/2020/10/13/us/nypd-election-protest-deployment/index.html
EFTA00025391


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=== Page 1 ===
From
To
Cc
Subject: RE: Relativity-- saved searches
Date: Wed, 14 Oct 2020 15:06:30 +0000
Inline-Images: image001.jpg
Thanks!
From
Sent: Wednesday, October 14, 2020 9:34 AM
To:
Cc:
Subject: RE: Relativity-- saved searches
The below searches have been created and available for review:
Search Requests
Search 01
Search 02
Search 03
Search 04
Search 05
Please let me know if there are any questions.
Thank you.
From
Sent: Friday, October 9, 2020 6:47 PM
To:
Cc:
Subject: Relativity-- saved searches
Hi
Hope you're doing well. For the relativity database "U.S. V. Epstein (SW Returns)," could you please create the following as
five separate saved searches:
Search 1: Any email (including attachments) that hits on the email address:
Search 2: Any email (including attachments) that hits on the email address:
Search 3: Any email (including attachments) that hits on the email addresses
or
EFTA00026808

=== Page 2 ===
Search 4: Any email (including attachments) that hits on the email addresses:
or
Search 5: Any document or family of documents containing either the word "Maxwell" or the word "Ghislaine"
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00026809


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Exhibits FILED"
Date: Thu, 10 Sep 2020 23:29:15 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 09/10/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
EXHIBITS, volume(s) 1 of 7, on behalf of Appellant Ghislaine Maxwell, FILED. Service date 09/10/2020 by
CM/ECF.[2928289] [20-3061]
Notice will be electronically mailed to:
Ty Gee, -:
Adam Mueller, -
Laura Menninger, -:
Mikaela N Cardenas, -
Notice will be stored in the notice cart for:
Mikaela N Cardenas, -
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Exhibit A
Original Filename: Exhibit A to Motion to Consolidate.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/10/2020] [FileNumber=2928289-0]
[c0bc42585a7daa44c53a7dd3907f8f53ec4b8ab210069ccb2bf8f3253329c2c8d641fd560b7844239329faf97248cf9
EFTA00023745

=== Page 2 ===
c5274e023c44f41206c5f4c310f3625909]
EFTA00023746


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
June 7, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to provide an update regarding the
defendant's conditions of confinement at the Metropolitan Detention Center ("MDC") pursuant to
the Court's Order dated December 8, 2020. (Dkt. No. 92). This update is based on information
provided to the Government by MDC legal counsel regarding the conditions of the defendant's
confinement over the last two months.
The defendant continues to receive more time to review discovery than any other inmate
at the MDC. Specifically, the defendant is permitted to review her discovery thirteen hours per
day, seven days per week. During the entirety of that time, the defendant still has access to both a
desktop computer provided by the MDC and a laptop computer provided by the Government on
which to review discovery. Also during those thirteen hours per day, the defendant may use the
MDC desktop computer to send and receive emails with her attorneys. This discovery review
takes place in a day room that is separate from the defendant's assigned cell. Accordingly, the
defendant continues to be permitted out of her cell from 7am to 8pm every day. While in the day
room, the defendant continues to have exclusive access to the MDC desktop computer, the laptop,
a television, a phone on which to place social or attorney calls, and a shower. The defendant is
EFTA00025219

=== Page 2 ===
Page 2
also permitted outdoor recreation every day, although she has the option of declining such
recreation time if she wishes.
The defendant also continues to receive as much, if not more, time as any other MDC
inmate to communicate with her attorneys. Currently, the defendant receives five hours of video-
teleconference ("VTC") calls with her counsel every weekday, for a total of 25 hours of attorney
VTC calls per week. All of these VTC calls take place in a room where the defendant is alone and
where no MDC staff can hear her communications with counsel. During these VTC calls, MDC
staff place a camera approximately 30 feet away from the door to the room where the defendant
conducts the VTC calls. The camera has a full view of the door to the VTC room, but the camera
does not capture any sound from the defendant's VTC calls with her attorneys. The defendant is
also permitted to use the phone in the day room to place phone calls to her attorneys as needed.
In addition, the defendant receives in-person visits from her attorneys as needed on
weekends. These meetings take place in a room where the defendant is alone with her counsel and
where no MDC staff can hear the defendant's communications with counsel. During these visits,
MDC staff place a camera approximately 30 feet away from the door to the attorney visit room.
The camera has a full view of the door to the attorney visit room, but the camera does not capture
any sound from the defendant's meetings with her counsel.
Like any other inmate, the defendant is patted down by MDC staff whenever she is moved
to a different part of the facility. As part of every pat-down search, the defendant is required to
open her mouth briefly so that MDC staff can confirm she has not hidden contraband in her mouth.
These pat-down and mouth searches continue to be consistent with MDC's policy that all inmates
be searched whenever they move to a different location within the jail facility. Also like all other
inmates, after each in-person visit she receives, the defendant is strip searched.
EFTA00025220

=== Page 3 ===
Page 3
After any in-person visit the defendant receives, MDC staff conduct a body scan of the
defendant, which is a non-invasive machine scan, to check for any secreted contraband. MDC
staff also search the defendant's cell for contraband approximately once per day. Finally, as
discussed in detail in the Government's May 5, 2021 letter (Dkt. No. 270), MDC staff conduct
wellness checks on the defendant every fifteen minutes at night to confirm that the defendant is
breathing. The MDC continues to be of the view that all of these searches are necessary for the
safety of the institution and the defendant, including for the reasons detailed in the Government's
May 5, 2021 letter.
MDC medical staff and psychology staff continue to monitor the defendant daily. Most
recently, MDC medical staff weighed the defendant on June 3, 2021 and found that she weighs
approximately 138 pounds. MDC medical staff continue to assess that the defendant is physically
healthy.
Should the Court have any questions or require any additional details regarding this topic,
the Government will promptly provide additional information.
Respectfully submitted,
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Cc: All Counsel of Record (By ECF)
EFTA00025221


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: Accepted: Gov't reply to Epstein bail motion due
Date: Wed, 10 Jul 2019 05:49:58 +0000
Importance: Normal
Attachments: unnamed
EFTA00026647


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=== Page 1 ===
Event: Accepted: Call w/ DOJ re. Epstein SDNY Investigation
Start Date: 2020-10-05 18:45:00 +0000
End Date: 2020-10-05 19:15:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2020-10-05 14:34:47 +0000
Date Modified: 2020-10-05 14:34:47 +0000
Priority: 5
DTSTAMP: 2020-10-05 14:20:43 +0000
Attendee:
EFTA00026581


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c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
Cc:
)"
(USANYS)"
,
)"
Subject:
&
Fact Witness Travel Request for Trial
Date: Fri, 19 Nov 2021 18:16:33 +0000
Attachments:
_Fact_Witness_Travel_Request_(for_trial).docx
Hi
Attached is the fact witness request form for
and
I'll give you a call shortly to discuss.
Thanks,
EFTA00024901


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 11164814(1) approved by
now awaiting further approval
Date: Mon, 04 May 2020 16:06:34 +0000
Importance: Normal
Dear
Final voucher 11164814(1) has been approved by
now awaiting further approval.
Trip ID: 11164814
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13444 - Epstein Investigation - Witness interview
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Pending Voucher Approval
Voucher total expenses: 308.30
Estimated trip cost: 574.30
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025494


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c3: VOL00008
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Epstein FOIA Next Steps - Noel Team
Date: Tue, 13 Apr 2021 18:52:13 +0000
I'm only free from 10:07 until 10:11. But you can fill me in.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
Cell:
On Apr 13, 2021, at 2:48 PM,
(USANYS)
wrote:
Now only free from 10:00 to 10:03, but will extend it to 10:04 for you,
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:46 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Don't change your plans. We'll make 10 am work to accommodate
important and busy schedule.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:13 PM
To:
(USANYS)
i
(USANYS)
i
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
I have plans this evening, but if 6pm is the only time, I can do it then.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:11 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Have a proffer then, sorry.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:10 PM
To:
(USANYS)
is
(USANYS)
EFTA00026922

=== Page 2 ===
Cc:
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
That window works for me.
?
From:
(USANYS)
Sent: Tuesday, April 13, 2021 2:09 PM
To:
(USANYS)
Cc:
(USANYS)
in
(USANYS)
Subject: Re: Epstein FOIA Next Steps - Noel Team
I'd have to move something but can do if nothing else works. I am wide open between 12 and 3 if there's anything good
during that time.
Sent from my iPhone
On Apr 13, 2021, at 1:26 PM,
(USANYS)
wrote:
Tomorrow morning fairly booked for me, but do have 10-10:30 if that's better for everyone.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:26 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
This afternoon isn't ideal. I can do 6pm if absolutely necessary, but I would prefer any time tomorrow morning.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:10 PM
To:
(USANYS)
is
(USANYS)
;
(USANYS)
Subject: RE: Epstein FOIA Next Steps - Noel Team
Doesn't work for me. Could you do 6pm?
Original Appointment
From:
(USANYS)
Sent: Tuesday, April 13, 2021 1:09 PM
To:
(USANYS);
(USANYS);
(USANYS)
Subject: Epstein FOIA Next Steps - Noel Team
When: Tuesday, April 13, 2021 4:00 PM-4:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where:
:
please let me know if this time doesn't work
has availability tomorrow as well. Thanks.
Please use dial in
, with passcode
EFTA00026923


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=== Page 1 ===
From
To: BOBBI C STERNHEIM
Christian Everdell
aura
Menninger
"Jeff Pagliuca"
Subject: RE: US V. Maxwell -Trial Start Date
Date: Tue, 11 May 2021 00:57:31 +0000
Attachments: 2021-5-10_Govt_Letter_re_Proposed_Trial_Date_Final.pdf
Hi Bobbi,
We filed the letter on ECF earlier this evening. Attached is a courtesy copy.
Best,
From: BOBBI C STERNHEIM
Sent: Monday, May 10, 2021 8:11 PM
To:
Christian Everdell
Laura
Menninger
eff Pagliuca
Subject: Re: US V. Maxwell -Trial Start Date
Do you have an ETA on the letter?
Thanks-
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.
EFTA00024664

=== Page 2 ===
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
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.
EFTA00024665

=== Page 3 ===
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 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
**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.
EFTA00024666

=== Page 4 ===
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. 550 (AJN)
We are available to begin November 8th and to conclude by the end of the year.
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.
EFTA00024667

=== Page 5 ===
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,
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
EFTA00024668

=== Page 6 ===
**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
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
EFTA00024669

=== Page 7 ===
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,
vrote:
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,
EFTA00024670


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: GM Exhibits
Date: Mon, 11 Oct 2021 15:29:56 +0000
Attachments: Copy_of_US_v_Maxwell_Government_Exhibit_Index_(internal)
(
).xlsx
Here's the updated index. Thanks,
From:
Sent: Monday, October 11, 2021 11:23 AM
To:
is
;
Cc:
is
Subject: RE: GM Exhibits
Thanks, could you please also redact
address and phone number on GX 607?
From:
Sent: Monday, October 11, 2021 11:15 AM
To:
is
Cc:
is
is
Subject: RE: GM Exhibits
All below changes have been made on the shared. Will update the index accordingly once you're done W edits. Thanks!
From:
>
Sent: Sunday, October 10, 2021 10:49 PM
To:
V.
Cc:
is
is
Subject: GM Exhibits
Sunny,
Thank you so much for all of your work on the exhibits. I made some edits directly in the index (saved on the shared and
attached here). Some notes below on exhibits and the index. As noted in my prior email,
is going to update the
index tomorrow morning to indicate which exhibits we intend to offer under seal. She may also have some other
comments/edits on exhibits and/or the index in the morning. As always, call or email with any questions. Thank you!!
10Series
I didn't update the spreadsheet, but I noticed a few things.
When I look in the folder, as I see it now
GX-10 - MV2
EFTA00026696

=== Page 2 ===
GX-11 - MV6
GX-12 - MV1
GX-13 - MV4
GX 10 isn't listed in the spreadsheet.
Remove MV-5 entry for now from index; when we get the certificate we will update
300 series
Remove GXs 316 and 331 and move up the last exhibits in the series to fill the gap
GX 313 - photo of GM including nudity (just making sure you see for redacting). Please cut "(nude)" from the
description in the index, please. Add the appropriate asterisk.
400 series
Do the word documents in native form (417A through 422A) have the old metadata?. Just want to be sure of this
and asking because I see that it might be different based on properties when I looked
There is no GX 419. Can you please fill the gap? Or shift things up? Sorry about that!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
EFTA00026697


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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, 07 Jan 2021 17:05:33 +0000
Good afternoon Bobbi:
We have receive your concerns and will be looking in to these matters.
All concerns will be properly addressed as needed.
Best,
BOBBI C STERNHEIM
1/6/2021 2:38 AM
Counsel for Ghislaine Maxwell learned that she has been issued a
disciplinary charge. Please provide a copy of the Incident Report.
Members of the same team who physically mistreated and threatened Ms.
Maxwell on Sunday now claim that she is not tidy (See email below.)
The basis of the charge is unclear - because Ms. Maxwell has not
deviated from her routine of the past 7 months. But the fact that it
comes after Ms. Maxwell and counsel made complaints
about staff is concerning, disturbing, and questionable.
The policy of rotating in staff from other institutions has contributed
to lack of consistency and clarity in the management of Ms. Maxwell. One
team tells her one thing which is then contradicted by another team.
One team tells her she can't keep books in her locker; another team
tells her to put books in her locker. One team tells her to keep a set
of clothes in her isolation cell; another team faults her for doing so.
Ms. Maxwell's request for guidance is met with a terse response: "Read
the A&O handbook."
Ms. Maxwell cannot ask other inmates for help and is at the mercy of
guards who appear to delight is their power over her. The present team
was particularly harsh during a previous rotation and seem to have
increased their contempt for Ms. Maxwell.
Ms. Maxwell- and counsel- are concerned for her safety while in the
custody of the present team.
In lieu of an opportunity for Ms. Maxwell to be moved to another unit,
and the unlikelihood that she would be
transferred to the MCC as a result of Epstein's death while BOP was
"asleep" on the watch, we are requesting that the present team be
removed from guarding Ms. Maxwell.
Issues still remain concerning Ms. Maxwell's meals. still is not
receiving items on the menu.
Yesterday, she received the same meal for lunch and dinner. Tuesday
morning she was given an inedible black and rotting banana. Over the
weekend she was given bologna, despite being on a non-flesh diet. The
guard informed her that the meat had not been refrigerated and
recommended that she not eat it.
The MDC's inability to provide proper nutrition is reoccurring and
EFTA00024888

=== Page 2 ===
problematic.
The problems keep escalating, giving rise to the belief that Ms.
Maxwell is being targeted and victimized. I urge you to address and
correct these problems. The failure to do so will
result in a request for court intervention.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
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 Jan 4, 2021, at 7:07 PM, BOBBI C STERNHEIM
wrote:
> Counsel for Ghislaine Maxwell (02879-509) write to report that she
was physically mistreated and verbally threatened by MDC staff over the
weekend.
> Officer
(sp) performed a body search of Ms. Maxwell inside her
isolation cell with her back to the handheld camera.
> During the search, Officer
squeezed Ms. Maxwell's breast with
vice-like pressure equivalent to a mammography.
> Ms. Maxwell physically recoiled in response to pain caused by Officer
Another guard, Officer
(sp)
> threatened to charge Ms. Maxwell with "assaulting an officer" should
she move again during a search of her person.
> Ms. Maxwell reported the physical incident to a staff psychologist
and to an associate warden and was examined by
> medical staff. In addition to written reports, the physical and
verbal incidents should have been captured on the hand-held
> camera, used constantly to surveil Ms. Maxwell.
> This is not the first time Ms. Maxwell has been touched
inappropriately by MDC staff, as MDC records should reflect.
V
> Counsel for Ms. Maxwell make this report to put the MDC on notice:
> Should Ms. Maxwell be further assaulted and threatened, we will file
an official complaint with the Attorney General's Office and notify the
Court. This will further blemish the BOP's reputation, already tarnished
by negligence resulting in the death of Jeffrey Epstein. The
restrictive conditions of Ms. Maxwell's detention in the MDC correlate
directly to the Epstein debacle in the MCC, making unprovoked rough
treatment of Ms. Maxwell baffling.
V
> Be further advised, should Ms. Maxwell face any retaliation as a
result of this email, this too will be promptly reported.
>
EFTA00024889

=== Page 3 ===
> BOBBI C. STERNHEIM, ESQ.
> Law Offices of Bobbi C. Sternheim
> 33 West 19th Street - 4th Floor
> New York, NY 10011
V
> 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.
EFTA00024890


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=== Page 1 ===
90A-NY-3151227 Serial 10
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023584
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023584: One (1) Seagate Constellation ES
500GB HDD, ST500NM0011, S/N Z1M1PZPE, from MCC Nice Vision DVR2
Surveillance System (7 of 18).
Item Type
Description
1B Digital
(U) NYC023584: One (1) Seagate Constellation ES 500GB
HDD, ST500NM0011, S/N Z1M1PZPE, from MCC Nice Vision
DVR2 Surveillance System (7 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023976


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Call this week
Date: Tue, 31 Mar 2020 18:43:55 +0000
I think everybody can handle a conference line! l'll send the update now, with thanks in advance to
for the use
of her numbers.
From:
Sent: Tuesday, March 31, 2020 14:42
To:
Cc:
Subject: Re: Call this week
I can join, but don't want to over complicate by having to switch to a conference line, so you guys go ahead, no worries.
Thanks.
Sent from my iPhone
On Mar 31, 2020, at 2:28 PM,
wrote:
Yes, I can join.
On Mar 31, 2020, at 2:07 PM,
wrote:
Are either / both of you able to join? No problem if not, I can just receive the update, but great if you're around. If all
of us can do it, I'll switch the invite from my number to
conference line (I need a login reset for my
USAVoice account otherwise I'd use mine).
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:54
To:
Cc:
is
Subject: RE: Call this week
That works. Please advise as to which number I should call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
EFTA00024279

=== Page 2 ===
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:51 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Yes, if that works for you - so in a little more than an hour. Or let us know if there's a different preferable time.
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:50
To:
Cc:
is
Subject: RE: Call this week
3P.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: Tuesday, March 31, 2020 10:46 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
That would be great, thanks. Would 3:00 work for you? Or please let us know if there's a more convenient time, we
can be flexible.
thanks again,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:31
To:
Cc:
is
Subject: RE: Call this week
EFTA00024280

=== Page 3 ===
May I call you with an update? What time today are you available for a call?
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: Tuesday, March 31, 2020 10:03 AM
To: Gloria Allred
Cc:
)
is
Subject: RE: Call this week
Gloria,
We were wondering if you or your colleagues have been able to reach any of the clients we discussed last week? It
would be very helpful to know their views and reactions shortly - and we're of course happy to speak with them
directly as well if that would be helpful.
thanks,
From:
)
Sent: Thursday, March 26, 2020 15:45
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Gloria,
Thanks for speaking with us just now. The individuals we mentioned are
Thanks,
Sent from my iPhone
On Mar 26, 2020, at 10:16 AM, Gloria Allred
wrote:
Thank you.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
EFTA00024281

=== Page 4 ===
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Thursday, March 26, 2020 7:12 AM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
We can use the below conference line:
Dial-in:
Code: 933571
Thank you,
On Mar 25, 2020, at 8:55 PM, Gloria Allred
wrote:
I would be happy to send a Zoom number to you or feel free to send me a conference number to call.
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 5:53 PM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Thanks very much. 3pm EST works for us. What number should we call?
Best,
EFTA00024282

=== Page 5 ===
On Mar 25, 2020, at 8:21 PM, Gloria Allred
wrote:
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,
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.
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.
EFTA00024283

=== Page 6 ===
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.
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.
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.
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.
EFTA00024284


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: [EXTERNAL] information
Date: Tue, 26 Oct 2021 08:23:34 +0000
I will follow up - I am in Scotland until thrusday
Sent from my iPhone
On Oct 26, 2021, at 1:33 AM,
wrote:
Hi Mr.
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and
note that you are specifically requesting what they released to the NYT. You can send me copy of that request
once it has been submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil
Division of our Office has received it. We do not handle FOIA requests in our division.
Best,
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
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.
EFTA00025058


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=== Page 1 ===
Event: Meeting with
on Epstein
Start Date: 2019-02-26 18:30:00 +0000
End Date: 2019-02-26 19:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2019-02-26 17:44:04 +0000
Date Modified: 2019-02-26 17:44:04 +0000
Priority: 5
DTSTAMP: 2019-02-26 17:29:16 +0000
Attendee:
(USANYS)
Alarm: Display the following message 15m before start
Reminder
EFTA00024486


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=== Page 1 ===
From:
To:
Subject: FW: Hard drive copy
Date: Tue, 13 Oct 2020 14:24:23 +0000
Attachments: Volume001.dat
Here is our latest correspondence - thank you so much!
From:
Sent: Friday, October 9, 2020 11:09 AM
To:
Cc:
Subject: RE: Hard drive copy
Hi
Attached is the data that needs to be added to the Maxwell hard drive copy, and then sent to
Please let me know if
there are any issues adding this to the drive.
Thanks so much, again - we really appreciate it!
From:
Sent: Friday, October 9, 2020 10:28 AM
To:
Cc:
Subject: RE: Hard drive copy
I apologize,
I did not - I was under the impression that the vendor would be sending you a physical copy. By the
time the vendor emailed us the files, I'd already given the original drive to
O start copying to a new drive.
if I send you that data, would you be able to add that to the copy as well?
Thanks,
From:
Sent: Friday, October 9, 2020 10:23 AM
To:
Cc:
Subject: RE: Hard drive copy
did you put the data that we got from the vendor on the hard drive. As it is needed for upload to Relativity.
Thank you.
EFTA00026806

=== Page 2 ===
From:
Sent: Friday, October 9, 2020 10:16 AM
To:
Cc:
Subject: RE: Hard drive copy
Hi
Thanks so much for all of your help yesterday! Whenever this Maxwell drive is copied, would you please send the copy to
so that he can upload it to the USvEpstein database on Relativity? I can pick up the original once it has finished
copying and I'm back in the office.
Thanks again,
and I hope you have a wonderful weekend!
From:
Sent: Thursday, October 8, 2020 12:31 PM
To:
Subject: Hard drive copy
Hi
,
I hope you're well! We received another hard drive that is to be loaded onto Relativity. Would you please make a copy of
this drive (I'll bring it down momentarily) so we can send it to to upload onto the USvEpstein database on relativity?
The password for the drive is: ScanningMaxwell!99
asks that the drive NOT be sent out to him until we get the overlay files we need from the vendor. Once the drive is
done copying, I can pick it up and keep it at my desk until the overlay files arrive from the vendor.
Thanks so much,
I'll be in the office today until around 3PM, and l'll be working remotely until Tuesday morning. I'll
be back in my office Tuesday.
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026807


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=== Page 1 ===
From: "etravelservices
To:
Subject: Final Voucher 10810811(1) prepared by a travel arranger is pending your review
Date: Thu, 21 Nov 2019 01:18:23 +0000
Importance: Normal
Dear
Final voucher 10810811(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10810811
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13176 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Santa Monica (City), CA, United States
Dates: 2019-11-14 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 740.28
Estimated trip cost: 1067.95
E2 Single Sign On Login (within DOJ Network Only):
E2 Manual Login (User ID and Password):
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
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.
EFTA00025100


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 28, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New York, NY
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY
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_02765768 through SDNY_GM_02766974.
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:
EFTA00024791

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02765768
SDNY GM 02765768
Scanned page of contact book
Confidential
SDNY GM 02765769
SDNY GM 02766967
Materials from Estate of Jeffrey Epstein¹
Confidential
SDNY GM 02766968
SDNY GM 02766974
Records from the United Kingdom
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
I These materials appear to be largely duplicative of materials previously produced to you in
discovery.
EFTA00024792


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=== Page 1 ===
Event: Accepted: Call re Epstein FOIA case
Start Date: 2021-06-04 16:00:00 +0000
End Date: 2021-06-04 16:30:00 +0000
Location: Dial-in:
; Code: 707522
Class: X-PERSONAL
Comment:
Date Created: 2021-06-04 13:02:26 +0000
Date Modified: 2021-06-04 13:02:26 +0000
Priority: 5
DTSTAMP: 2021-06-04 12:52:35 +0000
Attendee:
)
EFTA00025217


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=== Page 1 ===
From:
To:
Subject: transcript for readbacks
Date: Wed, 24 Mar 2021 15:21:58 +0000
Attachments: 2020-06-28,_Transcript.pdf.
Hi
Attached is the transcript that we'll use for readbacks in GJ.
Thanks,
EFTA00024169


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Cc:
)"
(USANYS)"
Subject: Fwd: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Date: Thu, 17 Sep 2020 15:08:28 +0000
Attachments: 20cr330_SEALED_Memo_Endorsement_9.17.20.pdf;ATT00001.htm
Attached is the decision from Judge Nathan.
Sent from my iPhone
Begin forwarded message:
From: Nathan NYSD Chambers
Date: September 17, 2020 at 10:59:14 AM EDT
To:
)"
Cc:
)"
i
(USANYS)"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Good morning,
Please find attached a memo endorsement signed by Judge Nathan, which will be filed under seal.
Respectfully,
Juan Ruiz Toro
Law Clerk to the Hon. Alison J. Nathan
From:
Sent: Wednesday, September 16, 2020 5:49 PM
To: Nathan NYSD Chambers
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Good afternoon,
Pursuant to Judge Nathan's September 15, 2020 memo endorsement order, attached please find a supplemental letter,
which the Government respectfully requests be filed ex parte and under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00023503

=== Page 2 ===
From: Nathan NYSD Chambers
Sent: Tuesday, September 15, 2020 2:47 PM
To:
)
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Good afternoon,
Please find attached a memo endorsement signed by Judge Nathan, which will temporarily remain under seal. Please
confirm receipt.
Respectfully,
Juan Ruiz Toro
Law Clerk to the Hon. Alison J. Nathan
From:
)
Sent: Monday, September 14, 2020 8:00 PM
To: Nathan NYSD Chambers
Cc:
is
(USANYS)
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Good evening,
Attached for Judge Nathan's consideration please find a letter pursuant to Federal Rule of Criminal Procedure 16(d)(1),
which the Government respectfully requests be filed ex parte and under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00023504


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=== Page 1 ===
90A-NY-3151227 Serial 9
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023583
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023583: One (1) Seagate Barracuda 500GB
HDD, ST3500320NS, S/N 9QM8EC75, from MCC Nice Vision DVR2 Surveillance
System (6 of 18).
Item Type
Description
1B Digital
(U) NYC023583: One (1) Seagate Barracuda 500GB HDD,
ST3500320NS, S/N 9QM8EC75, from MCC Nice Vision DVR2
Surveillance System (6 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023971


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=== Page 1 ===
From:
To:
Cc:
i
Subject: Fwd:
Date: Fri, 08 Jan 2021 12:23:52 +0000
Attachments: 2021.1.7_Letter_to_
FYI. I will still have the quick call with them this morning, as planned, but I will not get into a discussion about
the letter.
Begin forwarded message:
From: Susan Necheles
Date: January 7, 2021 at 11:46:05 PM EST
To:
,
"Kathleen E. Cassidy"
Cc:
Subject: RE:
I forgot to attach the letter.
From: Susan Necheles
Sent: Thursday, January 7, 2021 11:36 PM
To:
>; ; Kathleen E. Cassidy
is
Cc:
Subject: RE:
we had been working on this letter to send to
I wanted to send it to you before our conversation tomorrow so that you could understand our thoughts at this point.
Looking forward to speaking.
Susan
From:
Sent: Thursday, January 7, 2021 5:57 PM
To: Susan Necheles
>; Kathleen E. Cassidy
is
Subject:
EFTA00026959

=== Page 2 ===
All:
I hope all of you are doing well. Do you have a few minutes for a quick call tomorrow?
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00026960


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Tue, 14 Jul 2020 20:13:37 +0000
Inline-Images: image001.png
Just saw that the trial date for her is July 2021. Wow! And look at us with a seemingly never-to-be-scheduled
trial, ha!
On a serious note, don't want to step on any other paralegal's toes, but if you need help with anything with the Ghislane
case, happy to help out with whatever! If not, no worries, good luck with it all!
And miss you too! I miss seeing everyone. R X
From:
Sent: Thursday, July 2, 2020 5:29 PM
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Thanks so much
Miss you and hope all is well with you ©
From:
Sent: Thursday, July 2, 2020 1:26 PM
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats on this
Great job!
Hope you and your family are doing well!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO UNITED DONINER
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
ATTORNEY
EFTA00024481

=== Page 2 ===
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 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.
EFTA00024482

=== Page 3 ===
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
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.
EFTA00024483

=== Page 4 ===
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.
EFTA00024484


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=== Page 1 ===
From:
)"
To: Mariann Wang
Cc: Gloria Allred
Subject: RE: Another survivor
Date: Thu, 18 Mar 2021 03:09:11 +0000
That should work, thanks. Mind sending me the names and email addresses of participants, please?
Original Message
From: Mariann Wang
Sent: Wednesday, March 17, 2021 10:54 PM
To:
Cc: Gloria Allred
Subject: Re: Another survivor
Sure, how about April 2d at 12.30pm?
> On Mar 17, 2021, at 4:02 PM,
wrote:
>
> Hi Mariann,
>
> Hope you're well too, thanks. April 1 is pretty full on my end now. Would April 2 work for an interview with
this survivor, please?
>
> Thanks,
V
>
V
Original Message
> From: Mariann Wang
> Sent: Wednesday, March 17, 2021 8:48 AM
> To:
> Cc: Gloria Allred
> Subject: Another survivor
V
>
,
V
> I hope you're well. We have another survivor who would like to share her information/what happened to her. If
you're willing/open, perhaps we could just add her to April 1st, or let us know what you prefer. She is someone
who was abused by Epstein on one occasion in 2004.
V
> Thank you,
> Mariann
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein victim requests
Date: Tue, 03 Nov 2020 21:03:14 +0000
Attachments:
Hi
Per our call, please find attached the requests from
including names in footnotes, as well as the Masseuse
list document that I was looking at. I'm probably missing something, but I don't see the names on the list (with
the exception of
but the last name on the list doesn't match the requester's or is not included).
Thanks,
Original Message
From:
Sent: Tuesday, November 3, 2020 2:26 PM
To:
Subject: Epstein victim requests
Hi
Do you have time this afternoon for a brief call? I'm
if you have a moment.
Thanks!
Sent from my iPhone
EFTA00024796


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=== Page 1 ===
Event: Accepted: Epstein/Maxwell FOIA
Start Date: 2021-03-10 22:00:00 +0000
End Date: 2021-03-10 22:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2021-03-10 20:59:07 +0000
Date Modified: 2021-03-10 20:59:07 +0000
Priority: 5
DTSTAMP: 2021-03-10 20:28:24 +0000
Attendee:
(USANYS)
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: calls re: Epstein
Date: Wed, 10 Jul 2019 18:58:21 +0000
Importance: Normal
I am taking care of it.
From:
Sent: Wednesday, July 10, 2019 2:56 PM
To:
Cc:
Subject: RE: calls re: Epstein
Looping in Ed too since he just mentioned this to me also
From:
Sent: Wednesday, July 10, 2019 14:51
To:
Cc:
Subject: calls re: Epstein
Hi
It seems like a fair number of Epstein related calls are coming in through the main SDNY line, and we've set up a particular
line internally for those to be forwarded to. Would it be possible to let the CSOs to know that they should transfer any
incoming calls to the following extension, where they can leave a message? It's been set up so that those messages will
auto-forward to our whole team. The number is 212-637-1030.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
UBS
UBS Financial Services Inc.
26th Floor
New York NY 10171-0002
Tel
ubs.com/fs
Montpelier Trust
ATTN: Nutter McClennen & Fish
LLP
Boston, MA 02210-2698
January 3, 2019
Request: Please review the enclosed information and retain for your
records
Thank you for opening additional accounts with us.
As the final step in the account opening process, please review the Client Information and Account Information
sections of this package and confirm that they are accurate; if changes are required, please call us at the number
displayed above.
The Client Relationship Agreement and other account documents we provided when you opened a previous
account apply to your new accounts. Please refer to that information. Electronic versions are also available at
www.ubs.com/accountdisclosures.
Once again, thank you for the opportunity to serve you. At UBS, we value your relationship with us, and we
understand that we succeed only if you succeed.
Sincerely,
Scott Stackman I Lyle Casriel
UBS Financial Services Inc. is a subsidiary of UBS AG
Package ID: 0268296267 - 1
1
EFTA00024450

=== Page 2 ===
Intentionally Left Blank
Package ID: 0268296267 - 1
EFTA00024451

=== Page 3 ===
Client Information
Client Information
Client Information
Montpelier Trust
Trust Information
U.S. Federal law requires us
Trust Type
Irrevocable Trust
to obtain, verify and record
information that identifies
Name
Montpelier Trust
each person or entity
Jurisdiction
US Trust
that opens an Account with
us. When you open an
Date Established
07/31/2018
Account, we will ask for
Name of All Trustees
your name, street address,
date of birth and a tax
Christine Yvonne Malina-Maxwell
identification number, such
as a Social Security number.
Jeffrey W. Roberts
We may also ask to see a
Scott Borgerson
driver's license or other
documents that will allow
Name of All Grantors
us to identify you.
Ghislaine Maxwell
Please review and verify all
of the information that you
provided to us when you
Client Contact Information
opened your Account. If
you have changes,
corrections or additions,
Residential Address
ATTN: Nutter McClennen & Fish
notify your Financial Advisor
LLP
as soon as possible.
City, State, Zip Code
Boston, MA 02210-2698
If you share assets with
Home Phone
another person, the net
worth figure here shows
E-mail Address
your portion only, based
upon instructions you
Net Worth Information
provided.
Annual Income
Range from $200,000 $499,999
Investment Information:
This section reflects answers
Liquid Assets (cash and marketable securities)
Range from $10,000,000 AND ABOVE
you provided related to
Net Worth (excluding primary residence)
Range from $10,000,000 AND ABOVE
your investment experience,
market knowledge and
Federal Marginal Tax Rate
37% and above
other assets and is used to
ensure our investment
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
recommendations are
country outside of the United States.
suitable for your situation.
Investment Information
Years you have held investment accounts
None
Individual Stocks
None
Equities
None
Bonds
None
Futures
None
Options-Buy
None
Options-Sell
None
Knowledge of investments
None
Percentage of total investable assets held at UBS
More than 80%
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Package ID: 0268296267 - 2
3
EFTA00024452

=== Page 4 ===
Client Information
Client Information
Christine Yvonne Malina-Maxwell
Personal Information
U.S. Federal law requires us
Name
Christine Yvonne Malina-Maxwell
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Female
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Married
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
driver's license or other
Residential Address
documents that will allow
us to identify you.
City, State, Zip Code
Dallas, TX 75206-4307
Please review and verify all
Home Phone
of the information that you
E-mail Address
provided to us when you
opened your Account. If
you have changes,
Net Worth Information
corrections or additions,
notify your Financial Advisor
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
as soon as possible.
country outside of the United States.
If you share assets with
another person, the net
Investment Information
worth figure here shows
Years you have held investment accounts
8
your portion only, based
upon instructions you
Individual Stocks
None
provided.
Equities
None
Investment Information:
Bonds
None
This section reflects answers
you provided related to
Futures
None
your investment experience,
market knowledge and
Options-Buy
None
other assets and is used to
Options-Sell
None
ensure our investment
recommendations are
Knowledge of investments
You have indicated you have a good understanding
suitable for your situation.
of financial markets and market investments.
Percentage of total investable assets held at UBS
None
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Package ID: 0268296267 - 2
4
EFTA00024453

=== Page 5 ===
Client Information
Client Information
Jeffrey W. Roberts
Personal Information
U.S. Federal law requires us
Name
Jeffrey W. Roberts
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Male
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Married
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
Residential Address
driver's license or other
documents that will allow
City, State, Zip Code
Wenham, MA 01984-1464
us to identify you.
Home Phone
Please review and verify all
E-mail Address
of the information that you
provided to us when you
opened your Account. If
Net Worth Information
you have changes,
corrections or additions,
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
notify your Financial Advisor
country outside of the United States.
as soon as possible.
Investment Information
If you share assets with
another person, the net
Years you have held investment accounts
13
worth figure here shows
your portion only, based
Individual Stocks
None
upon instructions you
Equities
None
provided.
Bonds
None
Investment Information:
This section reflects answers
Futures
None
you provided related to
Options-Buy
None
your investment experience,
market knowledge and
Options-Sell
None
other assets and is used to
ensure our investment
Knowledge of investments
You have indicated you are an experienced investor
recommendations are
in financial markets and market investments.
suitable for your situation.
Percentage of total investable assets held at UBS
None
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Package ID: 0268296267 - 3
5
EFTA00024454

=== Page 6 ===
Client Information
Client Information
Scott Borgerson
Personal Information
U.S. Federal law requires us
Name
Scott Borgerson
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Male
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Single
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
Residential Address
driver's license or other
documents that will allow
City, State, Zip Code
Boston, MA 02108-1433
us to identify you.
Home Phone
Please review and verify all
E-mail Address
of the information that you
provided to us when you
opened your Account. If
Net Worth Information
you have changes,
corrections or additions,
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
notify your Financial Advisor
country outside of the United States.
as soon as possible.
Investment Information
If you share assets with
another person, the net
Years you have held investment accounts
23
worth figure here shows
your portion only, based
Individual Stocks
None
upon instructions you
Equities
None
provided.
Bonds
None
Investment Information:
This section reflects answers
Futures
None
you provided related to
Options-Buy
None
your investment experience,
market knowledge and
Options-Sell
None
other assets and is used to
ensure our investment
Knowledge of investments
You have indicated you are an experienced investor
recommendations are
in financial markets and market investments.
suitable for your situation.
Percentage of total investable assets held at UBS
None
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Package ID: 0268296267 3
6
EFTA00024455

=== Page 7 ===
Client Information
Client Information
Ghislaine Maxwell
Personal Information
U.S. Federal law requires us
Name
Ghislaine Maxwell
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Female
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Single
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
Client Contact Information
We may also ask to see a
driver's license or other
Residential Address
documents that will allow
us to identify you.
City, State, Zip Code
Boston, MA 02114-3252
Please review and verify all
Mobile
of the information that you
E-mail Address
provided to us when you
opened your Account. If
you have changes,
Employment Information
corrections or additions,
notify your Financial Advisor
Employment Status
Employed
as soon as possible.
Occupation
Other
If you share assets with
Occupation Industry
Other
another person, the net
worth figure here shows
Employer Name
The TerraMar Project
your portion only, based
Business Address
upon instructions you
provided.
City, State, Zip Code
New York, NY 10065 7007
Investment Information:
This section reflects answers
Net Worth Information
you provided related to
Annual Income
Range from $200,000 $499,999
your investment experience,
market knowledge and
Liquid Assets (cash and marketable securities)
Range from $10,000,000 AND ABOVE
other assets and is used to
ensure our investment
Net Worth (excluding primary residence)
Range from $10,000,000 AND ABOVE
recommendations are
Federal Marginal Tax Rate
37% and above
suitable for your situation.
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
country outside of the United States.
Investment Information
Years you have held investment accounts
24
Individual Stocks
None
Equities
23
Bonds
23
Futures
7
Options-Buy
12
Options-Sell
12
Knowledge of investments
You have indicated you are an experienced investor
in financial markets and market investments.
Percentage of total investable assets held at UBS
Less than 20%
Other
Own Home or Rent?
Own
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
Package ID: 0268296267 4
7
EFTA00024456

=== Page 8 ===
Client Information
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Client Information
Package ID: 0268296267 - 4
8
EFTA00024457

=== Page 9 ===
Account Information
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections
LLP
For more information, please
City, State zip
Boston, MA 02210-2698
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive: Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
Supreme Court Justice,
High Risk
member of the Joint Chief's
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
Investment Objective
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
Longer than 10 years (through several market cycles)
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
UBS FDIC INSURED DEPOSIT PGM
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
Secondary Sweep Fund
LIQUID ASSETS GOVERNMENT FUND
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Package ID: 0268296267 5
9
EFTA00024458

=== Page 10 ===
Account Information
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Account Information
Other Income Source
transfer
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
Package ID: 0268296267 - 5
10
EFTA00024459

=== Page 11 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections.
LLP
For more information, please
City, State zip
Boston, MA 02210-2698
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
Supreme Court Justice,
High Risk
member of the Joint Chief's
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
Investment Objective
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
Longer than 10 years (through several market cycles)
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
UBS FDIC INSURED DEPOSIT PGM
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
Secondary Sweep Fund
LIQUID ASSETS GOVERNMENT FUND
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Package ID: 0268296267 6
11
EFTA00024460

=== Page 12 ===
Account Information
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Account Information
Other Income Source
transfer
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
Package ID: 0268296267 6
12
EFTA00024461

=== Page 13 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
Account Address
ATTN: Nutter McClennen & Fish
corrections.
LLP
For more information, please
City, State zip
Boston, MA 02210-2698
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
High Risk
Supreme Court Justice,
member of the Joint Chief's
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
Investment Objective
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
7- 10 years
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
UBS FDIC INSURED DEPOSIT PGM
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
Secondary Sweep Fund
LIQUID ASSETS GOVERNMENT FUND
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Package ID: 0268296267 7
13
EFTA00024462

=== Page 14 ===
Account Information
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Account Information
Other Income Source
transfer
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
Package ID: 0268296267 - 7
14
EFTA00024463

=== Page 15 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections.
LLP
For more information, please
City, State zip
Boston, MA 02210-2698
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
High Risk
Supreme Court Justice,
member of the Joint Chief's
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
Investment Objective
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
7- 10 years
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
UBS FDIC INSURED DEPOSIT PGM
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
Secondary Sweep Fund
LIQUID ASSETS GOVERNMENT FUND
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Package ID: 0268296267 8
15
EFTA00024464

=== Page 16 ===
Account Information
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Account Information
Other Income Source
Transfer
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
Package ID: 0268296267 - 8
16
EFTA00024465

=== Page 17 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
Account Address
ATTN: Nutter McClennen & Fish
corrections.
LLP
For more information, please
City, State zip
Boston, MA 02210-2698
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
Yes
this particular account is defined
as:
You have agreed that the Margin Agreement in the Completing Your Account Opening Process
Moderate Willing to accept
some risk to principal and tolerate
package governs your use of margin in this account and all other accounts you have now or any
some volatility to seek higher
accounts that you may open in the future. As described in the Margin Agreement, certain securities
returns.
in your Account may be loaned to UBS or to other persons or entities.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Produce a Combination of
Features and Services
Income and Capital
Appreciation: Investments
Premier- RMA / BSA
seeking both the generation of
income and growth of principal.
In accounts with conservative
Account Objectives and Risk Profile
or moderate risk profiles,
investment eligibility
Account Risk Profile
Moderate
considerations help us
Your answers to our profiling questions:
identify whether you may be
Risk Tolerance
Moderate Risk
eligible to invest in certain
higher risk securities as a
Investment Objective
Produce a combination of income and capital
portion of your portfolio.
These investments offer
appreciation
additional diversification.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
A senior political official is
Investment Time Horizon
7 10 years
defined as a President or Vice
President, Cabinet Member,
Short-Term Liquidity Needs
No
Supreme Court Justice,
Sweep Account Election
member of the Joint Chief's
Staff, Member of Congress or
Primary Sweep Fund
UBS FDIC INSURED DEPOSIT PGM
a Parliament, Chairperson,
Head or Senior Leader of a
Sweep Cap Election
No
major religious organization,
or the like.
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
Secondary Sweep Fund
LIQUID ASSETS GOVERNMENT FUND
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Package ID: 0268296267 9
17
EFTA00024466

=== Page 18 ===
Account Information
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Account Information
Other Income Source
transfer
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
Package ID: 0268296267 - 9
18
EFTA00024467

=== Page 19 ===
Account Information
Account Information
RMA Domestic TRUST
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Montpelier Trust
Advisor immediately if you
have any changes or
ATTN: Nutter McClennen & Fish
Account Address
corrections.
LLP
For more information, please
City, State zip
Boston, MA 02210-2698
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Cards and Checks for this account, if requested, will
ATTN Nutter McClennen
be mailed to this address:
and Fish LLP
Please note: the account risk
Boston, MA 02210-2695
profile and investment
objective below are specific only
Primary Account Holder
Montpelier Trust
to this account other accounts
may have different account risk
UBS will not disclose your name, address and security
profiles and investment
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
objectives.
Account.
Your Account Risk Profile for
Margin
No
this particular account is defined
as:
If you did not choose Margin when you opened this account, you may ask to establish margin by
Aggressive Willing to accept
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
high risk to principal and high
Account Opening Process package will govern your use of margin in this account and all other
volatility to seek high returns over
time.
accounts you have now or may open in the future.
Different accounts may have
different risk profiles
Cost Basis Method
First In,First Out
Your Investment Objective,
Features and Services
Achieve Capital Appreciation:
Investments seeking growth of
Premier- RMA / BSA
principal rather than the
generation of income.
Account Objectives and Risk Profile
A senior political official is
Account Risk Profile
Aggressive/Speculative
defined as a President or Vice
Your answers to our profiling questions:
President, Cabinet Member,
Risk Tolerance
Supreme Court Justice,
High Risk
member of the Joint Chief's
Achieve capital appreciation (emphasis on growth of
Staff, Member of Congress or
Investment Objective
capital, not on income)
a Parliament, Chairperson,
Head or Senior Leader of a
Risk/Return Objectives
Higher Fluctuations, Higher Returns
major religious organization,
or the like.
Investment Time Horizon
7- 10 years
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
UBS FDIC INSURED DEPOSIT PGM
Sweep Cap Election
No
You have indicated that all beneficiaries for this trust are individuals (natural persons) or not-for-profit
organizations.
Secondary Sweep Fund
LIQUID ASSETS GOVERNMENT FUND
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Package ID: 0268296267 10
19
EFTA00024468

=== Page 20 ===
Account Information
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Account Information
Other Income Source
Transfer
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Conditions of this service.
E-mail Address
Anticipated Activity
According to our records, you have indicated the following expected activity in your account.
Anticipate depositing funds from third parties into account
No
Anticipate withdrawing from account to pay / transfer to third parties
No
Package ID: 0268296267 - 10E
20
EFTA00024469


c1: EFTA00026640
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026640.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
>
To:
>,
>,
Subject: RE: FW: conditions in SHU
Date: Mon, 08 Jul 2019 18:19:41 +0000 +
We are only away from our desks between 10 and 1 for a tour tomorrow.
>>>
(USANYS)" <
> 7/8/2019 2:18 PM >>>
I know
is going to be tied up for much of today. What are some good times tomorrow that work for you?
Assistant United States Attorney
From:
Sent: Monday, July 8, 2019 2:08 PM
To:
is
(USANYS)
is
is
(USANYS)
Subject: RE: FW: conditions in SHU
Hi all,
How does 2:45 or 3 sound? Would tomorrow be better? Time got away from me playing catch-up on all I missed last week.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
p:
f:
>>>
)"
>
7/5/2019 2:10 PM >>>
Thanks
Any time after 1:30pm should work.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026640

=== Page 2 ===
From:
Sent: Friday, July 5, 2019 1:38 PM
To:
is
(USANYS)
V.
)
is
(USANYS)
Subject: Re: FW: conditions in SHU
Hi
is out today and I'm not sure what his schedule is for Monday. Is there a particular time that works (or doesn't work)
for you?
Thanks,
Vessella
Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, NY 10007
p:
f:
>>>
)"
>
7/5/2019 1:24 PM >>>
We should discuss this issue as well as the cellphone on a call on Monday.
what times would work for you on
Monday?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Bruce Barket
Sent: Friday, July 5, 2019 1:02 PM
To:
is
Cc:
)
is
(USANYS)
>; ; tonyricco
(
)
>; ; Aida Leisenring
Subject: conditions in SHU
Good afternoon,
EFTA00026641

=== Page 3 ===
As I think you all know Nick has been placed in SHU based on an allegation that he was in possession of a cell phone. If
true, I understand that some appropriate and proportional sanction may be in order.
Leaving that aside I want to address the conditions in his cell. The toilet is leaking and the floor is wet. As of Wednesday,
he hasn't received his personal property, including his books. He has been sitting in the cell with literally nothing to read,
listen to or watch. Can we please make an effort to get him reading material, his radio and the accompanying batteries.
Most troubling is that he tells me that the legal work he had out when he was removed from the cell has not been returned
to him. This included documents prepared for him by my office which contained substantial and sensitive work product
that falls squarely within the attorney client privilege. Nick made notes on some of these documents to prepare for our
next meeting. When I saw him Wednesday, he had some of his legal paperwork but not the documents he was working
with when he was taken from the cell. I am very concerned that these documents have been seized by the staff at MCC.
Can you please take steps to see to that all of this material be returned to him immediately.
Lastly, I am hoping we can find time early next week to discuss the conditions of Nick's confinement going forward.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
[P]
[F]
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please
notify us immediately by telephone or email and immediately delete this message and all its attachments
EFTA00026642


c1: EFTA00027000
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00027000.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Epstein search warrant documents
Date: Tue, 07 Jul 2020 21:41:00 +0000
See below from the CART guy. It does seem we're making some progress. We plan to pick up the drive tomorrow, will
keep you posted.
From:
(NY) (FBI)
Sent: Tuesday, July 7, 2020 5:14 PM
To:
)
y.
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Everything with the exception of a couple of items are ready. I will get you an actual number before I send it over.
We can send it over tomorrow. There will be ReadMe files included so it will be easy to see where the items came from. I
am a little worried about how the e-mail will present. While looking through on a spot check, the attachments are not
connected to the e-mails in the forensic tool. I believe it is a function of the e-mail client they were using to begin with. I
know that the attachments are a concern of yours. We may have to massage things a bit to get it right. Now that we are
working every day, and everything has been processed, it shouldn't be too big a deal. So far the export is about 350 GB. It
copies slowly because it is a ton of pretty small files. You are getting the whole ball of wax, here, Macs, Windows boxes,
loose media, etc. There will be a few iPhone and iPad reports, but unsure if I can get you those tomorrow as they very
often take a LONG time to copy. Again, lots of small files. If not tomorrow, the next day.
Are you around tomorrow? Reach out to me when you get the production so we can correct any problems we might
encounter. Thanks.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, July 07, 2020 3:42 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
is
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
EFTA00027000

=== Page 2 ===
I understand that some number of the devices are ready to come to us as early as today or tomorrow. Could you please
let us know the following information, so we can figure out who the hard drive should go to in the first instance:
How many total devices are coming to us in this initial production?
What are those devices - i.e., type of device and which ones, from the spreadsheets you've sent?
What's the total volume of data coming in this round of production?
Once we know that, I can let the agents know where the drive needs to go in the first instance.
thanks,
From:
)
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
i
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
in
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
)
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
EFTA00027001

=== Page 3 ===
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll be
able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
i
(NY) (FBI)
is
>;
)
in
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
in
)
Cc:
(USANYS)
i
(NY) (FBI)
V.
)
is
)
in
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many
items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI materials? I
think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and USVI?
EFTA00027002

=== Page 4 ===
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per my
discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as 1 item in
particular has over 500,000 emails. We will be able to provide discovery once Defense Council has provided
drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let you know when
everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could you
please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this
week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything that
was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you
and
figured out a way to categorize the prior productions so they're useful for us? We would strongly prefer to just
get everything at once in a usable format, but please let us know if you expect to produce materials differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
is
(NY) (FBI)
i
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
EFTA00027003

=== Page 5 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
>;
)
is
)
>;
(NY) (FBI)
in
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
EFTA00027004

=== Page 6 ===
Cc:
(NY) (FBI)
i
is
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
EFTA00027005

=== Page 7 ===
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
EFTA00027006

=== Page 8 ===
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
>;
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00027007

=== Page 9 ===
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
EFTA00027008

=== Page 10 ===
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
EFTA00027009

=== Page 11 ===
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
>;
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
V.
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
V.
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
>;
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
=
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
EFTA00027010

=== Page 12 ===
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
)
>;
is
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
EFTA00027011

=== Page 13 ===
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
in
>;
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
EFTA00027012

=== Page 14 ===
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
EFTA00027013

=== Page 15 ===
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
i
in
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
>;
is
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
EFTA00027014

=== Page 16 ===
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
EFTA00027015

=== Page 17 ===
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
in
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00027016


c1: EFTA00026586
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026586.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Jill Greenfield
Cc:
)"
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Date: Tue, 06 Oct 2020 19:32:13 +0000
Inline-Images: image001.jpg; image002.png; image003.png
Not a problem, we will get tested tomorrow, we just wanted to check to make sure it was fine that we aren't getting
tested closer to flying - given the lag in receiving results, we think tomorrow makes the most sense.
Thanks,
From: Jill Greenfield
Sent: Tuesday, October 6, 2020 3:25 PM
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
Thanks
I'm so sorry. I have asked but have yet to receive a response. I suspect yes is safer. I hope that is ok. Sorry
about this.
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
f
in
Sent from my iPhone
On 6 Oct 2020, at 20:21,
wrote:
Hi Jill,
Following up on our conversation, I was wondering if you had any updates on the testing issue we discussed. Our team is
planning to get tested tomorrow in order to make sure we have results before flying, but please let us know as soon as
you can if that timing is a problem for some reason.
In addition, my cell phone number
and my phone will be working while I'm traveling. l'll also be
reachable by email.
Thanks,
From:
Sent: Monday, October 5, 2020 10:36 AM
To: Jill Greenfield
is
)
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi Jill,
EFTA00026586

=== Page 2 ===
Thank you very much for letting us know. We want to make sure your client is as comfortable as possible. It would be
very useful to our investigation to have more members of our team present for the interviews, but we will of course
defer to her comfort level. Let's discuss on our call tomorrow and make a final plan for the interviews then.
The process on our end does not require that we be tested before we depart.
and I are asymptomatic, have never
been symptomatic, and have not come into contact with anyone who was symptomatic or a known carrier, so we have
not been tested. That said, if you/your client would like us to get tested before we leave the U.S., there is a clinic near
our office that has been able to provide results within a day or two, so we could go there to get tested this week.
Best,
Assistant United States Attorney
Southern District of New York
From: Jill Greenfield
Sent: Monday, October 5, 2020 6:18 AM
To:
)
is
)
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi
I spoke to my client over the weekend. I suspect you will get rather more out of her if the number is kept to 2. I think otherwise she
may be overwhelmed.
As part of the process at your end will you be taking tests before leaving the US?
Kind Regards,
Jill
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
From:
Sent: Friday, October 2, 2020 9:44 AM
To: Jill Greenfield
is
)
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Thanks very much, Jill.
We are obtaining a waiver of the quarantine requirement from the UK government so that we will not be required to
isolate. If your client is not comfortable with four of us attending, we will of course defer to her preference and have a
smaller number travel to the UK. Please let us know what she prefers.
Meeting at your office works for us, thank you. We do not yet know whether the Met Police will need to be in the
building, but we will let you know as soon as we learn those details.
Is there a good time on Monday or Tuesday of next week when we might schedule a call?
Best,
Assistant United States Attorney
Southern District of New York
EFTA00026587

=== Page 3 ===
From: Jill Greenfield
Sent: Friday, October 2, 2020 4:40 AM
To:
)
is
)
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Many thanks
I will need to check with my client re 4 members of your party attending. Are you not having to isolate?
I can organise meeting rooms at my office.
I am happy to have a call next week to finalise matters.
Could you confirm if the Met police will also need to be in the building?
Kind regards,
Jill
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
From:
Sent: Thursday, October 1, 2020 9:21 PM
To: Jill Greenfield
is
)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Thanks, Jill. A few follow-up questions for you:
First, we are obtaining clearance for four members of our team to travel to London. Those would be
myself, FBI
Special Agent
and FBI Task Force Office
,
All four of us were on the video call with your client
the other day, so she has seen our faces. Please let us know if she is not comfortable with that group, so that we can
plan accordingly.
Second, would you like to meet at your offices, or would you like us to look into other arrangements?
Third, would you be available for a call next week in preparation for our trip?
Best,
Assistant United States Attorney
Southern District of New York
From: Jill Greenfield
Sent: Thursday, October 1, 2020 3:42 PM
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
Great, I should warn you that we may be going into lockdowns in London. Very tricky
EFTA00026588

=== Page 4 ===
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
Sent from my iPhone
On 1 Oct 2020, at 19:37,
wrote:
Hi Jill,
Thanks very much. Let's block off those dates for now and plan to meet then, if that's okay, and we will let you know if
for some reason those dates are not approved or if that's an issue.
Thanks,
From: Jill Greenfield
Sent: Thursday, October 1, 2020 2:29 PM
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
Hi. Apologies. I pressed and have just had confirmation for 14,15 and 16 if possible?
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
Sent from my iPhone
On 1 Oct 2020, at 17:31,
wrote:
Hi Jill,
Thanks for letting us know. Do you think you'll be able to let us know today about the dates we've proposed?
Apologies for pestering, but we can't move forward with travel arrangements without them, and the process we're
initiating requires a considerable amount of lead time before traveling once we start it.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, September 30, 2020 2:16 PM
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
I'm aware. That's fine. They may also need to be in the building.
Jill Greenfield
Partner
EFTA00026589

=== Page 5 ===
Click here for information relating to Covid-19 business impacts
Sent from my iPhone
On 30 Sep 2020, at 19:11,
wrote:
Thanks very much, Jill. In addition, we have learned that our embassy would be required to notify the Met Police
that we are meeting with your client. We wanted to check with you to make sure you are okay with us making that
notification, which we are told is standard practice for interviews conducted abroad.
Thanks,
Sent from my iPhone
On Sep 30, 2020, at 1:26 PM, Jill Greenfield
wrote:
Ok - understood - let me find out
thanks
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
From:
Sent: Wednesday, September 30, 2020 6:22 PM
To: Jill Greenfield
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi Jill,
With apologies for pressing, I wanted to follow up on these dates. As it turns out, we'll need proposed dates
before we can move any further in the approval process. If you could please let us know whether these dates
work for you as soon as you can, we'd be very grateful.
Thanks,
From:
Sent: Tuesday, September 29, 2020 3:29 PM
To: 'Jill Greenfield'
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi Jill,
Thanks very much for taking the time to (virtually) meet with us last week, we very much appreciated the chance
to speak with your client. We have been working on seeking approvals for a potential meeting with your client in
EFTA00026590

=== Page 6 ===
London in the coming weeks. Although we won't know whether the meeting is ultimately approved until we
complete the process, we are working on the issue in the hopes of making this possible.
It would be very helpful to us in the approval process to be able to propose specific dates for a meeting. We
would suggest that we set aside three days for successive meetings, if that works. Would you and your client be
available for meetings on October 14th, 15th, and 16th? Alternatively, we would propose the 20th, 21ˢᵗ, and 22nd.
If you could please let us know your availability, we'd very much appreciate it, and we'll keep you updated when
we have more information.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, September 16, 2020 4:04 AM
To:
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi
I rather assumed that you were not able to travel given the inherent difficulties with that and how you would be able to
meet with people in the UK without having to self-isolate first.
Let me know when is good for you for a video conference call.
Kind regards
Jill
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
From:
Sent: Wednesday, September 16, 2020 12:23 AM
To: Jill Greenfield
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Jill,
Thanks very much for reaching out. We would be glad to schedule a videoconference with your client to discuss
her questions and concerns. Are there particular dates and times that would work best for you and your client?
We are in the process of looking into the current rules on travel for government employees, and will let you know
as soon as we have more information. Our team is willing to travel if we are permitted to, but we're not yet
certain whether that is possible.
Thank you,
Assistant United States Attorney
Southern District of New York
From:
)
Sent: Tuesday, September 15, 2020 2:18 PM
To: Jill Greenfield
Cc:
is
is
EFTA00026591

=== Page 7 ===
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Jill,
We're very gratified to hear that your client is willing to speak with us, and we would be happy to answer her
questions as best we can.
In terms of logistics, I recently moved to a new position within our office and so the current team has been
updated - the investigation is now being handled by
and
whom you've spoken with previously,
as well as new addition
who also has extensive experience in these types of cases-they're all
copied here. They'll follow up with you to schedule a time for the discussion, and they can let you know the latest
status on any anticipated approvals for Government foreign travel (which I believe currently is prohibited for us,
otherwise we would be happy to travel to meet in person).
Thank you very much for your continued assistance in connection with our investigation, and I expect
and
will be in touch shortly as well.
thanks again,
From: Jill Greenfield
Sent: Tuesday, September 15, 2020 13:46
To:
Subject: Epstein [FFW-DOCS.FID6003375]
Hi
My client would like to speak to you to discuss matters. This would be in the form of her asking how you would manage this.
She did also ask if you were travelling to the UK at any point so. I said not but if I am wrong please do let me know.
Thanks
Jill
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your contact at
our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the sender immediately, destroy the
email and any attachments and do not use, copy, store or disclose this email and any attachments for any purpose. Fieldfisher does not accept service of documents by
electronic means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at www.fieldfisher.com
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and
regulated by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan
Lane, London EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00026592


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=== Page 1 ===
From:
To:
Subject: Final Voucher 11164814(1) prepared by a travel arranger is pending your review
Date: Mon, 04 May 2020 16:00:10 +0000
Importance: Normal
Dear
Final voucher 11164814(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 11164814
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13444 - Epstein Investigation - Witness interview
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Pending Voucher Approval
Voucher total expenses: 308.30
Estimated trip cost: 574.30
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
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.
EFTA00025493


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10643456-2 approved by
, now awaiting further
approval
Date: Fri, 27 Sep 2019 22:20:28 +0000
Importance: Normal
Dear
Travel authorization 10643456-2 has been approved by
, now awaiting further approval.
Trip ID: 10643456-2
Traveler name:
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-09-17 - 2019-09-20
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025334


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=== Page 1 ===
From:
To:
Laura Menninger
Jeff Pagliuca
Cc:
"
Subject: RE: Witness-3 - proposed redactions
Date: Sun, 21 Nov 2021 03:25:03 +0000
Attachments: 2021.11.11_Letter_to_Judge_Nathan_re_Response_to_Government_Letters_re_Accuser-
3_Evidence_[revised_proposed_redactions].pdf
Counsel - we have a corrected version of one of these filings regarding Witness-3. Attached are our proposed redactions.
Thanks,
From:
Sent: Saturday, November 20, 2021 9:50 PM
To:
Laura Menninger
; Jeff Pagliuca
Subject: Witness-3 - proposed redactions
Counsel,
Attached are our proposed redactions to the supplemental filings and order regarding Witness-3.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00024906


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=== Page 1 ===
From:
(NY) (FBI)"
To:
(NY) (OGA)"
(OIG)"
(USANYS)"
Cc:
(USANYS)"
Subject: [EXTERNAL EMAIL] - RE: Sign in SHU
Date: Mon, 27 Jul 2020 12:00:39 +0000
I'm with
- first I've seen of this as well. And I dont recall anyone saying anything about a sign.
-
On Jul 27, 2020 7:30 AM,
(OIG)"
wrote:
That is the first I am seeing that sign. I will check the 302s and MOIs to see if this was brought up.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
(Office)
(Cell Phone)
From:
(USANYS)
Sent: Sunday, July 26, 2020 11:11 PM
To:
(NY) (OGA) (FBI)
is
(NY) (FBI)
in
(OIG) <dcarpenter@OIG.USDOJ.GOV>
Cc:
(USANYS)
Subject: Sign in SHU
Hi folks,
I have a recollection that when we were interviewing employees at the MCC, one or more individuals told us there was
a sign posted in the SHU that said to do your checks on Epstein. If memory serves, we never recovered the document.
But last week we got a production of records from the BOP as part of FOIA litigation that included the attached. Can
you remind us (a) if there was in fact some employee who told us about this sign - I haven't looked at all the 302s and
MOIs, and (b) of anything we did to try to get this sign previously (if we did in fact make inquiries).
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:
Cell:
EFTA00025442


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=== Page 1 ===
Event: Declined: Epstein FOIA Next Steps - Noel Team
Start Date: 2021-04-13 20:00:00 +0000
End Date: 2021-04-13 20:30:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2021-04-13 20:27:41 +0000
Date Modified: 2021-04-13 20:27:41 +0000
Priority: 5
DTSTAMP: 2021-04-13 17:10:17 +0000
Attendee:
EFTA00026925


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Cc:
)"
Subject: RE: Epstein - Forfeiture
Date: Mon, 08 Apr 2019 17:59:17 +0000
Importance: Normal
Perfect, thanks very much.
From:
(USANYS)
Sent: Monday, April 8, 2019 1:54 PM
To:
is
(USANYS)
Cc:
Subject: RE: Epstein - Forfeiture
See attached.
Thanks,
From:
)
Sent: Monday, April 08, 2019 1:34 PM
To:
(USANYS)
Cc:
is
(USANYS)
Subject: Re: Epstein - Forfeiture
Not a problem at all, I'll work on this right now.
Sent from my iPhone
On Apr 8, 2019, at 1:32 PM,
(USANYS)
wrote:
Following up on our Brass meeting just now, It's that time of year when we need to do forfeiture funding requests.
These are basically short write-ups of cases that may involve forfeiture and are also likely to incur significant
investigative costs (e.g., traveling to Florida a dozen times, hiring a vendor retaining an expert). Could you guys do a
super quick Epstein write up this afternoon and send it back to me (unfortunately need to get these done today - sorry
for the short notice)? I've attached a blank form and a go-by (you'll see just how short these can be).
Also, notwithstanding what the form says, please do NOT email it down to DC - please send it back to me.
Thanks,
<FY20 Request Form- Large Case Related Expenses.docx>
FY19 Request Form - Large Case Related Expenses - 650 Fifth Fraud.docx>
EFTA00026691


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=== Page 1 ===
From: Jack Scarola
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: 12/04/09
VS Epstein Deposition Transcript
Date: Thu, 10 Sep 2020 19:46:13 +0000
Please let me know if you are able to locate the transcript.
On Sep 10, 2020, at 11:30 AM,
)
wrote:
Jack,
Thanks for your email. We will likely reach out to your adversary in the deposition to ask for a copy, but I wanted to check
to see whether you had already done so.
Thanks,
From: Jack Scarola
Sent: Wednesday, September 9, 2020 9:53 AM
To:
is
is
(USANYS)
Subject: Fwd: 12/04/09
VS Epstein Deposition Transcript
The email exchange below confirms our inability to locate the first volume of
deposition. However, attached are
fairly detailed notes of Paralegal/Investigator Mike Danchuk, who attended the deposition and recorded these notes
contemporaneously.
appears to have held nothing back, and the notes certainly paint a picture of the kind of
troubled young women who were particularly susceptible to Epstein's pattern of recruitment, grooming and
victimization.
Sent from my iPad
Begin forwarded message:
From: "Chris R. Rodgers"
Date: September 8, 2020 at 3:30:51 PM EDT
To: Jack Scarola
Cc: Mary McCann
"Wendy P. Calvet"
>,
"cmavsepsteinetalz6385257@projects.filevine.com" <cmavsepsteinetalz6385257@projects.filevine.com>
Subject: FW: 12/04/09
vs Epstein Deposition Transcript
Jack, below is the "Unable to locate" response from Prose Court Reporting. Visual Evidence, the videography
service used, also confirmed on Friday that a copy of the video is no longer available. I have attached Mike
Danchuk's notes from that deposition.
From: toni proseflorida.com
Sent: September 7, 2020 7:03 AM
EFTA00023536

=== Page 2 ===
To: Chris R. Rodgers
Subject: RE: 12/04/09
vs Epstein Deposition Transcript
Chris,
I have searched our records and archives and I am unable to locate Volume I of this deposition from
2009.
Sincerely,
Toni
|
Privileged and Confidential | Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is
not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00023537


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=== Page 1 ===
From:
To:
Subject: FW: Follow-up
Date: Wed, 15 Apr 2020 21:48:25 +0000
Forwarded without comment.
From: William Callahan
Sent: Wednesday, April 15, 2020 14:18
To:
Subject: Re: Follow-up
Attn:
)
Around last Dec 19, 2019, we corresponded re HRH Andrew -- and a potential role I could play having been
asked by my Investigative colleagues in London to try and act as his NY counsel. At the time I could not find
out what solicitors were representing him -- Around mid-March 2020, I learned that two British lawyers were
representing him: Gary Bloxsome, a London Solicitor who specialized in Extradition matters, and Clare
Montgomery, QC, a Barrister, also specializing in Extradition matters. I emailed both to see if I could get an
interest. Bloxsome never replied and
Paralegsal Clerk to Montgomery, emailed me back to
indicate she had read and acknowledged my email. No further responses since that time.
I am assuming that it is their intention to do nothing -- expecting that your investigation will not proceed. There
is no question in my mind that Andrew was deeply involved with Epstein and was very friendly with Ghislaine
Maxwell and likely is in touch with her now believed to be in Israel.
So, I wish you good luck and perhaps his counsel will reach back to me.
Bill Callahan
William P. Callahan
Attorney At Law
New York, NY 10016 (now working at home)
On Thu, Dec 19, 2019 at 12:16 PM William Callahan
wrote:
Will do
Thanks,
On Thu, Dec 19, 2019 at 12:14 PM
wrote:
Mr. Callahan,
Thank you for your email, and for speaking with me yesterday. As we discussed, we're not able to talk about
hypothetical representations, but to the extent you ultimately represent anyone who may have information in
connection with our ongoing investigation, please feel free to give us a call if/when that happens.
EFTA00026609

=== Page 2 ===
Best regards,
Assistant U.S. Attorney
Southern District of New York
From: William Callahan <
Sent: Thursday, December 19, 2019 11:10
To:
Subject: Follow-up
Attn: AUSA
Re: Epstein Matter
Confirming our tel-conference of yesterday and the Subject discussed, I expect it will take 3-4 weeks for me
to engage in discussions with Subject or his representative.
Thank you,
William P. Callahan
Attorney At Law
President, Unitel
New York, NY 10016
https://callahanandrobinson.com/lawyers/
www.unitel.com (click on British Flag)
Formerly U.S. Department of Justice
Member Association of Former Intelligence officers (AFIO)
Member, International Bar Association, London
EFTA00026610


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: RE: Epstein attorneys
Date: Mon, 04 Mar 2019 23:13:13 +0000
Importance: Normal
Sending this not because of the substance, but just because it may be notable (particularly given potential conflict issues
down the road) that none of his former attorneys still at Kirkland signed on -
https://www.nytimes.com/2019/03/04/opinion/letters/jeffrey-epstein.html
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
Office of the Inspector General
WARNINGS AND ASSURANCES TO EMPLOYEE REQUESTED
TO PROVIDE INFORMATION ON A VOLUNTARY BASIS
You are being asked to provide information as part of an investigation being conducted by the Office
of the Inspector General. This investigation is being conducted pursuant to the Inspector General
Act of 1978, as amended.
This investigation pertains to:
This is a voluntary interview. Accordingly, you do not have to answer questions. No disciplinary
action will be taken against you if you choose not to answer questions.
Any statement you furnish may be used as evidence in any future criminal proceedings or agency
disciplinary proceeding, or both.
WAIVER
I understand the warnings and assurances stated above and I am willing to make a statement and
answer questions. No promises or threats have been made to me and no pressure or coercion of
any kind has been used against me.
Signature of the Office of the Inspector
Employee's Signature
General Special Agent
Name of the Office of the Inspector
Employee's Name
General Special Agent
Signature of Witness
Date and Time
Name of Witness
Place
OIG Form III-226/2 (05/03/21) Non-Custodial/Employee
EFTA00025225


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: PCU Monthly Update
Date: Fri, 06 Nov 2020 19:34:27 +0000
Attachments:PC_Unit_Short_Form_Update.11.6.20.docx
Monthly update is attached, thanks.
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein OIG/FBI--Document Preservation
Date: Thu, 15 Aug 2019 21:33:52 +0000
Attachments: Jeffrey_Epstein_lit_hold_notice_form_08_12_2019.pdf
Dear all,
I'm sorry to pester but I think I haven't heard from you on this. Please complete and fill out the attached form by COB
tomorrow, and return to me.
It takes very little time. And failing to take care of this can really come back to bite us.
Many thanks,
PS apologies if you provided this and I overlooked it.
From:
Sent: Monday, August 12, 2019 5:13 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
Dear all,
As
explained, we are instituting a formal litigation hold in connection with Mr. Epstein's death at MCC. You have
been identified as having done work on or supervised the Epstein matter, and thus as possibly having responsive records.
EFTA00024004

=== Page 2 ===
Please note and preserve whatever you have about Mr. Epstein, not limited to his death and to the earlier reported
incident in which he suffered physical injuries. In addition, to the extent possible, please avoid altering any relevant
records. If you need to use existing documents, please save what you're working off of as a new document so that the
version that now exists remains preserved and available.
I attach a formal litigation hold notice, which as required is on an EOUSA-provided form. Please review the notice, fill out
the form to indicate whether and where you have responsive records, and sign and return it to me. In particular, be sure
to let me know by USAO number if possible what records and share directories we have that are likely to include relevant
information.
I prefer scanned and emailed return of the forms, but you can also use interoffice mail if you prefer.
Please let me know if you think other USAO personnel may have relevant documents or evidence.
And please let me know if you have questions or want to discuss.
Finally, I am copying
to inform him of the new litigation hold, and to ask him to ensure that all responsive
information on our electronic record systems is preserved, including by suspending the routine maintenance email
deletions for recipients of this email.
Many thanks,
Deputy Chief, Civil Division, and Litigation Hold Coordinator
U.S. Attorney's Office, S.D.N.Y.
New York, NY 10007
From:
Sent: Monday, August 12, 2019 4:46 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
FYI, as a result of a preservation request Epstein's lawyers have made on behalf of the family, which indicates a
potential wrongful death case, you will shortly be receiving a formal litigation hold request from
our litigation hold coordinator.
From:
Sent: Monday, August 12, 2019 11:43 AM
EFTA00024005

=== Page 3 ===
Subject: FW: Epstein OIG/FBI--Document Preservation
All - Please see below and follow
instructions. Additionally, if you believe there are others at SDNY to whom this
email should be sent, please let me know immediately.
Thanks,
From:
Sent: Monday, August 12, 2019 11:35 AM
Subject: Epstein OIG/FBI--Document Preservation
Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me:
Please make sure to preserve any documents you may have relating to Epstein's conditions of confinement.
Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let
me know if you have any or not.
If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know
that too.
Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way
or the other. If you do have anything, we'll figure out how to preserve that.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
New York. NY 10007
EFTA00024006


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=== Page 1 ===
7/6/19 'Location: 9 East 71st Street New York, NY-3rd Floor
#: 3/E-NI-3027571 Preparer: SA:
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EFTA00025132


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=== Page 1 ===
From:
To:
(USANH)"
)"
)"
Subject: RE: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Removal Hearing
Date: Mon, 06 Jul 2020 13:56:00 +0000
Thanks very much.
From:
(USANH)
Sent: Monday, July 6, 2020 9:55 AM
To:
is
is
Subject: FW: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Removal Hearing
FYI.
From: _bounce@nhd.uscourts.gov <ecf_bounce@nhd.uscourts.gov>
Sent: Monday, July 6, 2020 9:46 AM
To: nef@nhd.uscourts.gov
Subject: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Removal Hearing
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
e-mail because the mail box is unattended.
***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. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
U.S. District Court
District of New Hampshire
Notice of Electronic Filing
The following transaction was entered on 7/6/2020 at 9:45 AM EDT and filed on 7/2/2020
Case Name:
USA V. Maxwell
Case Number:
1:20-mj-00132-AJ
Filer:
Document Number: No document attached
Docket Text:
Minute Entry for proceedings held before Magistrate Judge Andrea K. Johnstone: REMOVAL
HEARING as to Ghislaine Maxwell held on 7/2/2020. The court found the defendant knowingly
and voluntarily waived and in-court hearing. Defendant: advised of rights and charges, waived
identity hearing. Detention hearing to be held in prosecuting district. (Court Reporter: Susan
Bateman) (Govt Atty:
)
(Defts Atty: Lawrence Vogelman) (USP: Janice
Bernard)( (Total Hearing Time: 17 min.) (kad)
EFTA00024772

=== Page 2 ===
1:20-mj-00132-AJ-1 Notice has been electronically mailed to:
S.
CaseView.ECF@usdoj.gov,
USANH.ECFCriminal@usdoj.gov, USANH.ECFDocket@usdoj.gov
1:20-mj-00132-AJ-1 Notice, to the extent appropriate, must be delivered conventionally to:
EFTA00024773


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=== Page 1 ===
From:
To:
Subject: Automatic reply: Epstein FOIAs
Date: Wed, 11 Mar 2020 13:48:46 +0000
I am currently on trial before the Honorable Paul A. Engelmayer. Although I will be checking emails, my responses may be delayed. For urgent
matters, please contact the other AUSA(s) on the case, or AUSA
EFTA00023779


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: GM photo on Bannon phone
Date: Mon, 14 Jun 2021 18:43:45 +0000
Thanks very much for flagging - no need to do anything with this one, but thanks for letting me know, and do let me know
if anything else pops up.
From:
Sent: Friday, June 11, 2021 12:31 PM
To:
Cc:
Subject: GM photo on Bannon phone
Hi
I hope you're well! I'm helping out with the responsiveness review for WBTW and I've been looking through Steve
Bannon's iPhone 7 on Cellebrite. As I was going through the images from that phone, I found an image of Trump and
Ghislaine Maxwell on Bannon's phone (see screenshot from Cellebrite, attached). I discussed with Sunny and we wanted
to flag this for you, in case it was of any importance to you, since you are on both cases.
Please let me know if you'd like anything further done with this. Thanks so much!
EFTA00025553


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
Subject: RE: Epstein - Forfeiture
Date: Mon, 08 Apr 2019 17:54:17 +0000
Importance: Normal
Attachments: Epstein_FY20_Request_Form-_Large_Case_Related_Expenses.docx
See attached.
Thanks,
From:
Sent: Monday, April 08, 2019 1:34 PM
To:
(USANYS)
Cc:
is
(USANYS)
Subject: Re: Epstein - Forfeiture
Not a problem at all, I'll work on this right now.
Sent from my iPhone
On Apr 8, 2019, at 1:32 PM,
(USANYS)
wrote:
Following up on our Brass meeting just now, It's that time of year when we need to do forfeiture funding requests.
These are basically short write-ups of cases that may involve forfeiture and are also likely to incur significant
investigative costs (e.g., traveling to Florida a dozen times, hiring a vendor retaining an expert). Could you guys do a
super quick Epstein write up this afternoon and send it back to me (unfortunately need to get these done today - sorry
for the short notice)? I've attached a blank form and a go-by (you'll see just how short these can be).
Also, notwithstanding what the form says, please do NOT email it down to DC - please send it back to me.
Thanks,
<FY20 Request Form- Large Case Related Expenses.docx>
<FY19 Request Form - Large Case Related Expenses - 650 Fifth Fraud.docx>
EFTA00026446


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
)"
,
)"
Subject: Re: Epstein SW returns
Date: Mon, 12 Oct 2020 17:26:48 +0000
The email you just forwarded us sounds like it's referring to what I was talking about- Marty is a different
attorney for Epstein.
Sent from my iPhone
On Oct 12, 2020, at 1:15 PM,
)
wrote:
I've never dealt with them. Have you or Alex been dealing with Marc or Andrew?
From:
Sent: Monday, October 12, 2020 1:06 PM
To:
)
Cc:
is
Subject: Re: Epstein SW returns
Marc Weinstein and Andrew Tomback represent the co-executors of the estate (Darren Indyke and
).
Sent from my iPhone
On Oct 12, 2020, at 12:55 PM,
wrote:
Who represents the estate?
From:
Sent: Monday, October 12, 2020 12:52 PM
To:
Cc:
i
Subject: Re: Epstein SW returns
Hi
Thanks- from what I remember, the estate communicated with you directly about this, so I don't remember getting a
list.
Sent from my iPhone
On Oct 12, 2020, at 12:38 PM,
> wrote:
Hi
Hope you're well too. Did Epstein's lawyers also give you the list of attorneys? And can you remind me who they
are?
EFTA00026834

=== Page 2 ===
Thanks,
From:
Sent: Monday, October 12, 2020 11:50 AM
To:
Cc:
i
Subject: Re: Epstein SW returns
Hi
Hope you're doing well, and thanks very much for your help with privilege issues for this review. In our review of this
database, we have come across some communications (emails and reports)from private investigators- among
others, an investigator named Roy Black. We are generally aware that Epstein hired private investigators in
connection with a criminal investigation and related civil litigation in Florida.
We don't know whether these materials are privileged. Could you possibly confer with the estate attorneys to
determine whether they are asserting a privilege over communications by private investigators? In the meantime, we
will stop reviewing the database unless we hear from you otherwise.
Thanks very much,
Sent from my iPhone
On Oct 12, 2020, at 10:53 AM,
wrote:
Thanks very much,
From:
Sent: Monday, October 12, 2020 10:51 AM
To:
Cc:
(
is
Subject: RE: Epstein SW returns
The Goldberger hits have been moved out.
Thanks,
From:
Sent: Sunday, October 11, 2020 5:14 PM
To:
Cc:
i
)
Subject: RE: Epstein SW returns
That is Jack Goldberger's email address. l'll ask to have the Goldberger hits pulled now and will let you know when
they are moved out.
From:
Sent: Sunday, October 11, 2020 12:52 PM
To:
Cc:
i
Subject: Epstein SW returns
EFTA00026835

=== Page 3 ===
Hi
For the Epstein search warrant database, I saw an email from the following email address that I wanted to flag for
further privilege review, because it may belong to Jack Goldberger, who represented Epstein:
Thanks,
EFTA00026836


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein call
Date: Wed, 29 Apr 2020 15:28:11 +0000
Importance: Normal
Attachments: unnamed
EFTA00025477


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=== Page 1 ===
From: "Weinstein, Marc A." <marc.weinstein@hugheshubbard.com>
To:
"ATomback@mclaughlinstern.com"
<ATomback@mclaughlinstern.com>
Cc:
Subject: RE: following up
Date: Mon, 12 Apr 2021 21:58:14 +0000
The Estate is asserting privilege with respect to materials on such devices.
Best regards,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York NY 10004-1482
Office +1 (212) 837-6460 I Cell +1 (646) 537-5750 Fax +1 (212) 299-6460
marc.weinstein@hugheshubbard.com
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Friday, April 9, 2021 10:29 AM
To:
>; Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>;
ATomback@mclaughlinstern.com
Cc:
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Marc and Andy,
I'm writing to ask for one point of clarification regarding the estate's position regarding the assertion of attorney-client
privilege. You previously conveyed to us that the estate asserted privilege with respect to devices the FBI seized from
Jeffrey Epstein's residences in New York and the USVI in 2019. We accordingly assembled a firewall team to conduct a
privilege review of the contents of those devices.
The FBI is also in possession of a computer that the Palm Beach Police Department seized from Epstein's residence in Palm
Beach in 2005, which our office has not reviewed. Is the estate also asserting privilege with respect to devices such as this
one that were seized in Florida in 2005?
Thank you,
EFTA00026910

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, March 31, 2021 1:59 PM
To: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>; ATomback@mclaughlinstern.com
Cc:
is
Subject: RE: following up
Thanks, talk to you then. We can use this conference line: 929-251-9612,1996301807##
From: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
Sent: Wednesday, March 31, 2021 1:52 PM
To:
>; ATomback@mclaughlinstern.com
Cc:
is
Subject: RE: following up
3:30 works for us.
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York I NY 10004-1482
Office +1 (212) 837-6460 I Cell +1 (646) 537-5750 I Fax +1 (212) 299-6460
marc.weinstein@hugheshubbard.com
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, March 31, 2021 1:35 PM
To: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>; ATomback@mclaughlinstern.com
Cc:
is
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Thanks very much- would it be possible to speak slightly later on Monday, perhaps at 3:30 or later? Alternatively, we're
available between 10:30 and 2 p.m. on Monday.
EFTA00026911

=== Page 3 ===
From: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
Sent: Wednesday, March 31, 2021 10:58 AM
To:
>; ATomback@mclaughlinstern.com
Cc:
is
Subject: RE: following up
Alison, how about Monday at 2:30pm?
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor New York I NY 10004-1482
Office +1 (212) 837-6460 I Cell +1 (646) 537-5750 I Fax +1 (212) 299-6460
marc.weinstein@hugheshubbard.com
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, March 31, 2021 9:33 AM
To: ATomback@mclaughlinstern.com; Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
Cc:
is
Subject: following up
CAUTION: This email was sent by someone outside of the Firm.
Marc and Andy,
Hope you're both doing well. Are you available for a call early next week? We wanted to follow up with you on an aspect
of our previous document requests.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
PRIORITIES WEBPAGE
SOUTHERN DISTRICT OF NEW YORK
Thwarting and Responding to Acts of Terror
The Office addresses a full range of threats to national security, domestic and international
terrorism, espionage, and large-scale international drug and arms trafficking. Working closely with
the New York Joint Terrorism Task Force and other law enforcement partners, prosecutors assigned
to the Office's Terrorism and International Narcotics Unit have obtained convictions in important
national security matters:
In May 2019, the Terrorism and International Narcotics Unit convicted Ali Kourani at trial for his
work as a covert operative for Hizballah's external attack-planning component.
In November 2018, the Terrorism and International Narcotics Unit charged Cesar Sayoc just days
after he mailed sixteen packages containing explosives to CNN, Hillary Clinton, and other public
figures in this District and across the country. In March 2019, Sayoc pled guilty to 65 felonies,
including use of weapons of mass destruction and interstate mailing of explosives. In August 2019,
Sayoc was sentenced to 20 years in prison.
In November 2018, the Terrorism and International Narcotics Unit convicted Akayed Ullah at trial
for detonating a pipe bomb during rush hour in the Port Authority Bus Terminal in support of ISIS.
In February 2018, Ahmad Khan Rahimi, the so-called "Chelsea Bomber," was sentenced to multiple
terms of life imprisonment following his trial conviction for his ISIS-inspired plot to detonate
powerful explosives in that densely populated Manhattan neighborhood.
The Terrorism and International Narcotics Unit investigated and charged Paul Rosenfeld in October
2018. Following his subsequent guilty plea, Rosenfeld has since been sentenced for offenses related
to his construction of a destructive device in his Tappan, New York, basement that he intended to
detonate on the National Mall on Election Day.
Enforcing International Sanctions
The Office is on the front lines of identifying and prosecuting individuals and entities that violate
U.S. and international sanctions.
In May 2019, the Office announced the first-ever seizure of a North Korean cargo vessel for violating
international sanctions. As detailed in the complaint, the "Wise Honest" was one of North Korea's
largest carrier ships and was used to export coal from North Korea and import machinery in
violation of U.S. and U.N. sanctions. The vessel was sold at auction on October 7, 2019.
In January 2018, the Terrorism and International Narcotics Unit secured the second of two
convictions against participants in a sprawling scheme to illicitly transfer billions of dollars of
Iranian oil money in violation of U.S. sanctions. In October 2019, the Office announced charges
against a Turkish bank for its alleged role in facilitating the sanctions-evasion scheme.
EFTA00023938

=== Page 2 ===
PRIORITIES WEBPAGE
SOUTHERN DISTRICT OF NEW YORK
In November 2018, the Money Laundering and Transnational Criminal Enterprises Unit announced
criminal charges and a $1.34 billion resolution against a large French bank for processing billions of
dollars in illicit funds in connection with credit facilities involving Cuba, in contravention of U.S.
law.
EFTA00023939

=== Page 3 ===
PRIORITIES WEBPAGE
SOUTHERN DISTRICT OF NEW YORK
Prosecuting Corrupt Public Officials
The Office holds public officials accountable by investigating and prosecuting abuses of office,
including quid pro quo bribery, embezzlement of public funds, civil rights violations, and other
criminal offenses perpetrated by public officials, law enforcement officers and others. Recent
prosecutions include:
Personal Attorney to the President Convicted of Campaign Finance Crimes, Tax Evasion and
Fraud: In August 2018, the Public Corruption Unit secured the conviction of Michael Cohen, the
former personal attorney to the President, upon a plea of guilty to a multi-count information. Of
note, Cohen pleaded guilty to making unlawful, excessive contributions to the 2016 presidential
campaign in the form of payments to two women to secure their silence regarding the then-
presidential candidate in order to prevent those stories from influencing the election. Cohen also
pleaded guilty to multiple counts of tax evasion in connection with his concealment of millions of
dollars in income from the IRS, and to making false statements to a financial institution. In
December 2018, Cohen was sentenced to 36 months' imprisonment.
Nine Defendants, Including Joseph Percoco, Former Executive Deputy Secretary to the Governor,
and Alain Kaloyeros, President Of SUNY Polytechnic Institute, Convicted of Federal Corruption and
Fraud Offenses: In September 2016, the Public Corruption Unit unsealed charges against two high-
ranking State officials, businessmen, and a corrupt lobbyist relating to multiple significant criminal
schemes affecting in the aggregate nearly $1 billion in State funds. In the first scheme, one of the
most powerful individuals in New York State's executive department - Joseph Percoco, the
Executive Deputy Secretary to the Governor - accepted bribe payments from a large energy company
and a real estate development company for his influence and action on multiple significant State
decisions. In the second scheme, Alain Kaloyeros, a public university president who was given vast
control by the Governor's office over State economic development projects engaged in a bid-rigging
scheme involving the Governor's centerpiece economic development initiative - known as the
Buffalo Billion - conspiring with businessmen to rig the bidding process for State-funded projects
worth hundreds of millions of dollars. After two trials, as well as guilty pleas, Percoco, Kaloyeros,
five businessmen, and the lobbyist were convicted.
Four New York City Police Department Officers Convicted of Bribery in Connection with Approving
Gun Licenses: Between 2017 and 2019, the Public Corruption Unit convicted four officers from the
NYPD's License Division for accepting bribes to approve, upgrade and expedite gun licenses,
including of individuals who would otherwise have been rejected on account of their criminal
history. The bribes included cash, sometimes handed over in envelopes or stuffed between pages of a
magazine, luxury travel, and other gifts. In addition to approving and expediting gun licenses, the
bribed officers often upgraded gun licensees to have full concealed carry rights in New York City
EFTA00023940

=== Page 4 ===
PRIORITIES WEBPAGE
SOUTHERN DISTRICT OF NEW YORK
without the proper justification. Those charge and convicted included Lieutenant Paul Dean, the
former Executive Officer of the License Division. Also convicted were four former "expediters" who
charged clients a fee to help them obtain gun licenses by bribing the officers, including a former
Assistant District Attorney.
In May 2018, prosecutors convicted Sheldon Silver, the former speaker of the New York State
Assembly, following a two-week jury trial on charges of wire fraud, mail fraud, extortion under color
of official right, and engaging in illegal monetary transactions all arising out Silver's improper use of
his position. The evidence at trial showed that Silver used his office position to obtain nearly $4
million in bribes in exchange for his official acts and another $1 million through laundering the
proceeds of his crimes. Silver was sentenced to seven years in prison.
In July 2018, following a jury trial, the Public Corruption Unit obtained convictions of Dean Skelos,
the former New York State Senate Majority Leader, and his son, Adam Skelos, on charges of bribery
and extortion. The proof at trial showed that Dean Skelos used his position to obtain more than
$300,000 in bribes and extortion payments that were made to Adam Skelos. Dean Skelos received a
sentence of 51-months imprisonment and Adam Skelos received a sentence of four years'
imprisonment.
Prosecuting Local Corruption
Christopher St. Lawrence, the former Ramapo Town Supervisor, engaged in a scheme to defraud
investors in Ramapo's municipal bonds by manipulating the Town's financial statements to create
the appearance that the Town was fiscally sound. He did so in order to obtain the financing he
needed to build Palisades Credit Union Park, a 3,500 seat minor league baseball stadium in Ramapo,
at a cost of more than $60 million. He was found guilty at trial and sentenced to 30 months in
prison. St. Lawrence's conviction marked the first prosecution for accounting fraud in connection
with municipal bonds.
Keith Borge, the former Controller for the College of New Rochelle, was convicted in 2019 of
engaging in a 20 million dollar payroll tax fraud and securities fraud scheme. Borge failed to pay
over to the IRS over 20 million dollars in payroll tax and covered up the resulting liability on the
college's financials. The college's bondholders were defrauded by the false financial statements. His
scheme contributed to the college's bankruptcy and closure.
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Human Trafficking and Sexual Exploitation of Minors
The Office prioritizes the investigation and prosecution of numerous child pornography, child
enticement, child endangerment, and sex trafficking offenses.
In July 2019, prosecutors charged Jeffrey Epstein with sex trafficking of minors between 2002
through 2005, Epstein sexually exploited and abused dozens of underage girls by enticing them to
engage in sex acts with him in exchange for money. Epstein allegedly worked with several employees
and associates to ensure that he had a steady supply of minor victims to abuse, and paid several of
those victims themselves to recruit other underage girls to engage in similar sex acts for money. The
indictment against Jeffrey Epstein was vacated following his death in August of 2019.
Beginning from a tip about the trafficking of minor victims in and around the New York City area
and a subsequent interview of one particular minor victim, the Office has successfully investigated
and prosecuted violent pimps who trafficked adults and minors--some as young as 13 years-old-who
were often part of the New York City social services system. The investigation has resulted in charges
against 19 defendants in eight separate indictments; to date, 15 of the defendants have been
convicted-two following jury trials and 13 by guilty pleas. The first defendant to be sentenced in
this matter, who was convicted following a May 2019 jury trial, received a sentence of 17 years'
incarceration, and the remaining convicted defendants face substantial sentences
In October 2018, the General Crimes Unit convicted Lavelleous Purcell after trial of five counts
related to his forced prostitution of multiple adult women. Purcell was sentenced to 188 months'
imprisonment.
In December 2018, Clint Edwards was sentenced to 20 years in prison for arranging to meet a 14-
year old child over social media and filming himself having sex with the victim in the basement of the
victim's apartment building.
In 2018, the White Plains Division secured a 32-year prison sentence for David Ohnmacht for
enticing a 14-year-old girl via Instagram to engage in sexual conduct and for engaging in this
criminal conduct while a registered sex offender.
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Combatting Gun and Gang-Related Violence
The Office, primarily through the work its Violent and Organized Crime Unit, also focuses on
prosecuting murders, and dismantling gangs and violent drug crews, with a particular emphasis on
violence prosecutions in the Bronx.
According to the New York City Police Department, in the first half of 2019 (as compared to the first
half of 2018) in the Bronx:
Murders were down 33%
Shootings were down 5%
The number of shooting victims was down 8.5%
In July 2018, prosecutors convicted Stiven Siri-Reynoso for the June 2016 murder of Jessica White,
who was killed by a stray bullet while watching her children play on a playground in the Bronx. Siri-
Reynoso was sentenced to life plus five years in prison.
In December 2018, Sean Peter, Jason Campbell and Steven Syder were convicted of the murder of
Brian Gray in the Bronx in October 2012 and for committing narcotics and firearms offenses. The
proof at trial showed that in retaliation for an attempted drug robbery, Peter, Campbell and Syder
followed Gray and three friends from a local bodega to a nearby porch on Barker Avenue in the
Bronx. After leaving the area to arm themselves, Peter, Campbell, and Syder returned and opened
fire fatally wounding Gray and injuring two other individuals. Peter was sentenced to 23 years in
prison, Campbell was sentenced to 23 years in prison, and Syder was sentenced to 20 years in
prison.
In March 2019, following a five-week jury trial, prosecutors obtained convictions of the leaders of the
Blood Hound Brims gang, one of the most violent and fastest-growing factions of the Bloods street
and prison gang that operated principally in New York City, upstate New York, Pennsylvania, and
throughout the New York State prison system. Three defendants - Latique Johnson, Brandon Green
and Donnell Murray -- were convicted of committing racketeering conspiracy, narcotics and firearms
offenses between 2005 and 2016. In addition, Johnson and Murray were found guilty of
committing assault in aid of racketeering for a 2012 shooting at a fast food restaurant in the Bronx
involving an AK-47 semiautomatic rifle. Johnson was found guilty of attempted murder in aid of
racketeering for ordering a 2012 shooting of rival gang members in the Bronx. The defendants are
awaiting sentencing. Ten other defendants pleaded guilty to serious crimes, including racketeering
and firearms offenses, arising out the same investigation.
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In June 2019, prosecutors convicted James Felton for two murders committed in the Bronx in
2016. The evidence at trial established that Felton was a member of a drug-distribution organization
operating in the Bronx. On June 11, 2016, at the corner of East 175th Street and Monroe Avenue in
the Bronx, Felton shot Marvin Harris 13 times, killing him, after Harris insulted Felton and
challenged Felton's status within the drug territory. Six months later, at the corner of East
175th Street and Weeks Avenue, one block away from the scene of the Harris murder, Felton shot a
rival drug dealer named Edwin Romero four times, then shot Jose Morales in the head, killing
him. Felton was also convicted of conspiring to distribute crack cocaine, heroin, cocaine and
marijuana and of related firearms offenses. Felton was sentenced to life plus 75 years in prison.
In 2018 and 2019, the Violent and Organized Crime Unit successfully prosecuted high-ranking
members of the Nine Trey Gangsta Bloods, a violent gang responsible for shootings, drug dealing,
robberies and numerous of acts of violence in Manhattan and Brooklyn. The investigation and
prosecution resulted in the conviction of 14 members and associates of Nine Trey, including a well-
known hip-hop music artist, Daniel Hernandez, a/k/a "Tekashi 6ix 9ine." Hernandez, who pleaded
guilty to racketeering, narcotics, and firearms-related offenses, testified in September 2019 at the
trial of two high-ranking Nine Trey members, Aljermiah Mack, a/k/a "Nuke," and Anthony Ellison,
a/k/a "Harv." Mack and Ellison were convicted of racketeering conspiracy in connection with their
gang membership. Ellison was also found guilty of kidnapping, maiming, and assault with a
dangerous weapon in connection with his membership in Nine Trey. Mack was found guilty of
conspiring to distribute more than one kilogram of heroin related to his gang activities. Both are
awaiting sentencing. Four other members of Nine Trey Gangsta Bloods, including the leader of the
gang, Jamel Jones, a/k/a "Mel Murda," have been sentenced. The remaining members and
associates are awaiting sentencing after having pleaded guilty to serious crimes.
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Protecting the Environment and Public Health
The Environmental Protection Unit in the Office's Civil Division protects the environment and public
health in this district (and beyond).
In June 2018, the Office sued the New York City Housing Authority for systematically violating lead
paint safety regulations, failing to provide sanitary living conditions as required by law, making false
statements about these conditions, and deceiving HUD inspectors. The lawsuit was resolved by
a historic settlement providing for the appointment of a federal monitor for NYCHA, imposing strict
compliance deadlines, and obligating New York City to provide billions of dollars to support
NYCHA's remedial efforts.
The Environmental Protection Unit represents the U.S. Environmental Protection Agency and other
federal agencies in a wide range of environmental enforcement matters in this district,
including Superfund, Resource Conservation and Recovery Act, Clean Water Act, and lead-paint
safety cases. One significant example is the Office's June 2018 lawsuit against the City of Mount
Vernon for failing to comply with Clean Water Act storm sewer permit requirements designed to
prevent raw sewage and other illicit pollutants from flowing from Mount Vernon's storm sewer
system into the Hutchinson and Bronx Rivers.
The Environmental Protection Unit also brings cases on behalf of the U.S. Department of Agriculture
and the Food and Drug Administration to protect food safety and eliminate other public health
threats. In June 2017, for example, this Office sued to shut down a fish smokehouse that had
repeatedly been found to have Listeria bacteria in the facility as a result of recurring violations of
food safety regulations.
The Environmental Protection Unit also acts to ensure that companies cannot use bankruptcy to
avoid their responsibility for environmental contamination. In July 2019, this Office entered into a
settlement in In re Magnesium Corporation, which requires the debtors to pay more than $33
million for clean-up of a contaminated Superfund site. In addition, in 2014, this Office obtained
the largest ever litigation recovery by the government for clean-up of environmental contamination,
in the Tronox bankruptcy. That settlement included, among other things, more than $4.4 billion for
environmental clean-up and liabilities arising from contaminated sites across the country.
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Combating the Opioid Crisis
The United States faces an epidemic of overdoses and deaths from prescription and synthetic
opioids. The Office is committed to prosecuting those responsible for fueling this crisis. In addition
to targeting street-level dealers and their suppliers, the Office has aggressively pursued medical
professionals who divert these highly-addictive pills, including doctors, pharmacies, and a major
drug distributor.
In April 2019, in the first prosecution of its kind, the Narcotics Unit charged one of the nation's
largest drug distributors, Rochester Drug Cooperative, and two of the company's senior executives,
with distributing drugs that helped fuel the opioid epidemic. This case represents the first time
executives of a pharmaceutical distributor and the distributor itself have been charged with drug
trafficking. The charges are a reminder to drug companies and drug distributors of their
responsibilities to put public health before corporate profits and to adhere to the highest standards of
ethics and compliance in placing dangerous pharmaceutical products in the marketplace.
The Office has also been aggressive in prosecuting "dirty doctors" and other medical professionals
who have helped to perpetuate the opioid crisis.
In October 2018, the Narcotics Unit charged five doctors, one pharmacist, and a physician's assistant
as part of a coordinated takedown of trusted health professionals who abused their positions to
illegally sell oxycodone. The case against these defendants is pending.
In December 2018, the Unit convicted a Staten Island doctor who prescribed millions of oxycodone
pills to patients whom he knew had no legitimate need for the highly-addictive drug. He is scheduled
to be sentenced in January 2020.
In March 2018, the Complex Frauds & Cybercrime Unit charged five Manhattan based doctors for
accepting bribes and kickbacks from Insys, a pharmaceutical company, in exchange for prescribing
Subsys, a potent fentanyl-based spray. To date, four of the five doctors have been convicted; the
remaining charged defendant is awaiting trial in this case.
In addition to pursuing medical professionals, the Office has redoubled its enforcement efforts by
partnering with the New York City Police Department to establish the Overdose Response Initiative,
which treats every overdose as a crime scene and aims to hold drug traffickers responsible for their
roles in the opioid crisis. The Narcotics Unit has secured convictions of multiple individuals who
distributed drugs that caused overdoses.
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In one such case, in December 2018, the Narcotics Unit secured a 25 year prison sentence, following
the conviction at trial of an individual who sold heroin that resulted in two overdose deaths.
In May 2019, the Narcotics Unit convicted a Staten Island drug dealer who sold fentanyl-laced
heroin that led to two overdoses, one of which resulted in the death of a 26-year-old man.
Countering State-Sponsored Cybercrime
The Office has moved aggressively to investigate and prosecute cybercrime cases of national and
international significance.
In March 2018, the Complex Frauds & Cybercrime Unit unsealed charges against nine Iranians
associated with the Mabna Institute, which conducted a massive computer hacking campaign on
behalf of Iran's Islamic Revolutionary Guard Corps. The Mabna Institute is allegedly responsible for
stealing academic research, intellectual property, and other confidential business information from
144 U.S.-based universities, 176 universities in 21 foreign countries, 47 domestic and foreign private
sector companies, and several U.S. Government agencies, among other victims. The Mabna case was
the product of multiple federal and international agencies dedicated work to take down this state-
sponsored hacking group. Criminal charges were announced in coordination with sanctions imposed
by the Department of Treasury's Office of Foreign Asset Control, which designated the Mabna
Institute and its hackers for sanctions for conducting malicious cyber activities.
In December 2018, the Complex Frauds & Cybercrime Unit charged two Chinese nationals affiliated
with the Chinese-sponsored hacking group "APT10" with conducting extensive hacking campaigns
on behalf of the Chinese government to steal intellectual property and confidential business
information from more than 45 technology and defense companies. APT10, known as an "Advanced
Persistence Threat" group, compromised data held by managed service providers, firms that other
companies trust to store, process, and protect commercial data, including intellectual property and
other confidential business information.
In March 2016, the Complex Frauds & Cybercrime Unit charged seven Iranian nationals for
conducting a state-sponsored coordinated series of "Distributed Denial of Service attacks against the
U.S. Financial Sector between 2011 and 2013. The seven defendants were allegedly associated with
two Iran-based cybersecurity companies - ITSec Team and Mersad - that operated as fronts for the
Iran government's offensive cyber operations. During the campaign, the defendants leveraged large
botnets consisting of thousands of compromised servers around the world to systematically send
malicious Internet traffic to servers belonging to 46 U.S. banks, resulting in disabling the servers and
costing the banks tens of millions of dollars to remediate. Notably, the indictment separately
charged one of the ITSec Team defendants, Hamid Firoozi, with the 2013 compromise of the
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Supervisory Control and Data Acquisition systems of the Bowman Dam in Rye, New York. Had the
sluice gate (the gate that controls the flow of water released through the dam) not been disconnected
from the system for maintenance, the compromise would have allowed the Iranian government to
remotely control the operations of the dam.
Prosecuting Fraud
The Office's Criminal and Civil Divisions prosecute fraud on a wide scale. The Criminal
Division investigates and prosecutes cybercrime, complex frauds and white collar crimes, and
securities and commodities fraud. The Civil Division's Civil Frauds Unit uses civil enforcement
statutes to investigate and prosecute numerous types of misconduct, including financial fraud,
healthcare fraud, and program and grant fraud, and in recent years has obtained admissions of
wrongdoing from dozens of defendants and over $5 billion in recoveries on behalf of the federal
government. The Civil Frauds Unit and the Criminal Division's "white collar" units closely
coordinate with each other to maximize the recovery of criminal fraud proceeds and to return
that money to victims.
In October 2019, Representative Christopher Collins pleaded guilty to participating in a scheme to
commit insider trading and to making false statements to federal law enforcement agents. Prior to
his guilty plea, Collins had represented the 27th District of New York as a member of the U.S. House
of Representatives. His son Cameron Collins, and Stephen Zarsky also pleaded guilty to
participating in the insider trading scheme. Representative Collins, Cameron Collins and Stephen
Zarsky are awaiting sentencing.
In 2019, the Civil Frauds Unit filed and settled two healthcare fraud lawsuits against national
pharmacy chain Walgreens Boots Alliance, Inc. for a total of $269.2 million, relating to Walgreens's
improper billings to government healthcare programs. The Office alleged that Walgreens improperly
billed the government for insulin pens that patients did not need and made false representations to
Medicare, Medicaid, and other programs in connection with that practice, and also that Walgreens
sought and obtained reimbursement from Medicaid for prescription drugs at improperly inflated
prices.
In 2018, the Criminal Division's Complex Frauds & Cybercrime Unit pursued significant investment
fraud cases, including the prosecution of William "Billy" McFarland. McFarland was sentenced to six
years' imprisonment for, most notably, fraud in connection with promoting the notorious "Fyre
Festival" that left hundreds of ticket purchasers virtually stranded without food and shelter-not to
mention entertainment-on the beaches of Exuma, in the Bahamas.
In 2018, the Securities and Commodities Fraud Task Force charged three former employees of the
Public Company Accounting Oversight Board (PCAOB) and three executives at KPMG for their
alleged roles in a scheme to illegally obtain confidential PCAOB information and use it to improve
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KPMG audit performance. To date, three defendants have pleaded guilty and two defendants were
found guilty after trial. The remaining defendant is awaiting trial.
In 2018, the Securities and Commodities Fraud Task Force successfully prosecuted Craig Carton, a
nationally-syndicated sports talk radio host, for participating in a Ponzi scheme based on the
supposed purchase and resale of tickets to Hamilton and other major productions. Carton, who was
convicted following a trial, received a sentence of 42 months in prison.
In 2017, the Civil Frauds Unit obtained a judgment of over $296 million against the entities formerly
known as Allied Home Mortgage Capital Corporation and Allied Home Mortgage
Corporation (collectively "Allied"), in connection with their fraudulent misconduct while
participating in the Federal Housing Administration ("FHA") mortgage insurance program. After a
five week trial, a jury found that Allied falsely certified that thousands of high risk, low quality loans
were eligible for FHA insurance and submitted insurance claims to the U.S. Department of Housing
and Urban Development ("HUD") when any of those loans defaulted. In the same trial, the Office
also obtained a jury verdict, and $25 million judgment, against Allied's President and Chief
Executive Officer Jim C. Hodge for his participation in this fraudulent conduct.
In 2016, the Civil Frauds Unit obtained a $1.2 billion settlement of a False Claims Act and FIRREA
lawsuit against Wells Fargo Bank, N.A., and a Wells Fargo executive-the largest recovery ever in a
Federal Housing Administration mortgage fraud case. The Office alleged that, as a participant in the
FHA Direct Endorsement Lender program, Wells Fargo engaged in reckless underwriting practices
and intentionally failed to report seriously defective loans to HUD.
In 2016, the Office brought important criminal cases in the area of Medicare and Medicaid fraud,
such as U.S. v. Sajid Javed. Javed was convicted for operating nine pharmacies in the New York City
area that had submitted more than $8.5 million in fraudulent claims to Medicare and Medicaid for
prescription drugs that were not delivered to customers.
In 2015, the Civil Frauds Unit announced a coordinated $714 million settlement of civil lawsuits
brought by the United States and others against the Bank of New York Mellon, in connection with
allegations that the Bank engaged in fraud and other misconduct when providing foreign exchange
services to its customers. The Office's lawsuit alleged that, contrary to representations made by Bank
of New York Mellon to its clients that the Bank provided "best rates" and "best execution," the Bank
actually gave clients the worst reported interbank rates of the trading day.
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Protecting Civil Rights
The Office is a leader in the prosecution of civil and criminal cases to ensure the protection of civil
rights for individuals within the District.
In March 2019, as part of its continued enforcement work under the Americans with Disabilities Act,
the Civil Division's Civil Rights Unit helped secure a partial summary judgment that, if applied going
forward, would obligate the MTA to install elevators whenever it performs a subway station
renovation that affects the station's usability, regardless of cost.
In March 2019, the Civil Rights Unit resolved its sixteenth design and construction case under the
Fair Housing Act, by entering into a Settlement Agreement requiring Sutton Manor, a condominium
complex in Mount Kisco, to engage in extensive retrofits to make the individual units and common
areas of the complex more accessible to residents with disabilities. The Unit resolved a similar suit
against Webster Management in December 2018, and another such suit against Ginsburg
Development in April 2018.
In July 2018, the Civil Rights and Public Corruption Units obtained the conviction and sentencing of
New York State Correction Officers for the brutal beating of inmate Kevin Moore, and for falsifying
records to cover up the beating.
In November 2017, the Civil Rights Unit settled a race discrimination lawsuit against the New York
City Department of Transportation for a pattern and practice of Title VII violations, requiring the
City to pay $1.3 million in damages and revise its promotion policies.
In September 2017, the Civil Rights and Public Corruption Units secured a 30-year sentence for
Brian Coll, a New York City Correction Officer, following his conviction after a jury trial for beating
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an inmate, Ronald Spear, to death and for obstructing justice by covering up the true cause of Spear's
death.
In August 2017, the Civil Rights and Public Corruption Units convicted Rodiny Calypso, a New York
City Correction Officer, for filing a false report in connection with the assault of a handcuffed inmate
at Rikers Island.
Also in August 2017, the Civil Rights and Public Corruption Units secured the conviction and jail
time for New York State Correction Officer Jeffrey Green, who pleaded guilty to violating the
constitutional rights of an inmate by subjecting her to abusive sexual contact.
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