# docs_fts_content

c1: EFTA00016405
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016405.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Date: Thu, 05 Sep 2019 15:49:40 +0000
Importance: Normal
Thanks very much. We will likely meet at the same place as last time, but we haven't booked reservations yet. l'll let you
know once we confirm the location.
Thanks
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:45 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
EFTA00016405

=== Page 2 ===
Cc:
is
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or 13th work
best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this afternoon. I'll plan
to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check in to see if you still planned to travel south given the storm. Current estimates show a
landing (somewhere) Tuesday with very bad weather on Wednesday. Airports might close (which will
answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
EFTA00016406

=== Page 3 ===
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a hotel in West Palm
Beach, and l'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
EFTA00016407

=== Page 4 ===
Following up on scheduling, we were wondering if your client is available for a proffer on September 4th. We're
flexible on timing that day, but we would propose meeting at 12:30 p.m., if that works.
Thanks,
From: Joe Nascimento
>
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
)
is
Subject: Re:
)
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon (anytime after
1)? I have proactive cooperation ongoing in another case involving multiple jurisdictions, and they are looking to
meet the morning of 8/14. I understand if your schedule is already set, and will work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and we'll follow up
to firm up plans as we get closer. If there are any conflicts with that date, please let us know, we're happy to be
flexible.
EFTA00016408

=== Page 5 ===
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
I do not have any travel plans during the month of August, nor does
September is a busy month with two
trials set, and I will be traveling out of the country from Sept 17-30, but I will do everything to be as flexible as
possible.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you could please let
us know if there are any particular weeks that would not work for you or your client for a meeting in Florida (in
particular, we don't want to interfere with anyone's summer vacation plans).
EFTA00016409

=== Page 6 ===
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it would be
helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
>;
Subject: Re:
)
- Epstein
Hi
,
That works for me. Please call me on my cell
Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're available on Friday
at 2:30, if that works, but let us know if there are other times that would be more convenient for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good afternoon,
EFTA00016410

=== Page 7 ===
It was a pleasure to meet you yesterday. In light of the recent filing and media reports
As always, feel free to contact me at any time if we can be of further assistance. Look forward to meeting again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are here, and
we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
EFTA00016411

=== Page 8 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating logistics, and
we will let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors//2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
)
<mailto:
wrote:
EFTA00016412

=== Page 9 ===
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
mailto:
<mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors:.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com http//www.crimlawfirm.com -http:/www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
)
<mailto:
mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
)
mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
EFTA00016413

=== Page 10 ===
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors:/2/0> Avenue<x-apple-data-
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http//www.crimlawfirm.com -http:/www.crimlawfirm.com/
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com http//www.crimlawfirm.com-http:/www.crimlawfirm.com
From:
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on Tuesday -
you can reach us at
,
or we can also call you then if that's easier, whatever you prefer.
EFTA00016414

=== Page 11 ===
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
mailto:
<mailto:
<mailto:
mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for
Tuesday morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors:.//2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http//www.crimlawfirm.com -http:/www.crimlawfirm.com/
On Jul 7, 2019, at 4:04 PM,
)
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect
our schedules may be somewhat unpredictable tomorrow; would it work to set a time to talk on
Tuesday? We can schedule it for before you meet with
,
if that's helpful. Or if you'd like to
talk sooner, we could schedule a time later today, or check in tomorrow about a possible afternoon
discussion. Please let us know what you prefer, and we look forward to being in touch.
thank you,
EFTA00016415

=== Page 12 ===
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
i
mailto:
<mailto:
<mailto:
<mailto:
Cc:
mailto:
mailto:
Subject:
) - Epstein
My former partner, Alan Ross, represented
prior to his passing
in 2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's
former partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am
unable to meet with her until Tuesday, but I would appreciate a few minutes of your time at your
convenience as I am getting up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-apple-data-
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors.//2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com http://www.crimlawfirm.com/
EFTA00016416


c1: EFTA00015962
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015962.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Tentative: Epstein NY property
Start Date: 2020-07-16 17:30:00 +0000
End Date: 2020-07-16 18:00:00 +0000
Location: Skype Meeting; Conference ID: 612 758 867;
Class: X-PERSONAL
Comment:
Date Created: 2020-07-16 16:33:58 +0000
Date Modified: 2020-07-16 16:33:58 +0000
Priority: 5
DTSTAMP: 2020-07-16 15:59:36 +0000
Attendee:
EFTA00015962


c1: EFTA00014885
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014885.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Gail Goodman
To:
)"
Cc:
(USANYS)"
Subject: [EXTERNAL] Re: Expert Witness
Date: Thu, 25 Nov 2021 01:11:07 +0000
Attachments: Alexander_Quas_Goodman_nsf_ptsd_psych_science_pub_2005.pdf;
Goldfarb,_Goodman_Larson_N_30_Clinical_Psychological_Science_article_2018.pdf;
bidrose_and_Goodman_case_study_2000.pdf;
Goodman_Ghetti_Quas_NSF_disclosure_Psych_Science_article_2003.pdf;
Goodman_Quas_Goldfarb_et_al-2018-
Child_Development_Perspectives_article_2018_(1).pdf
Hello,
I have attached several articles of mine that provide a sense of my research findings, especially on long-term
memory for child sexual abuse experiences. I selected publications that are fairly "quick reads." I hope you find
them of interest. I can follow this up with my vita and some associated information later tonight. Thank you, and
Happy Thanksgiving!
Sincerely,
Gail Goodman
Distinguished Professor
On Wed, Nov 24, 2021 at 8:55 AM
)
wrote:
Dr. Goodman,
My colleagues,
,
and I are the prosecutors in the case of United
States V. Ghislaine Maxwell, which is scheduled to go to trial beginning on November 29, 2021 in the Southern
District of New York. We are reaching out because we would be interested in speaking with you about
consulting with us and potentially testifying at the trial. Would it be possible to schedule a call to discuss?
Thanks very much,
Assistant United States Attorney
Southern District of New York
EFTA00014885

=== Page 2 ===
New York, New York 10007
Gail S. Goodman
Distinguished Professor and Director,
Center for Public Policy Research
Department of Psychology
University of California
e-mail:
phone:
fax:
EFTA00014886


c1: EFTA00014669
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014669.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Laura Menninger
Jeff Pagliuca
BOBBI C STERNHEIM
"BOBBI C STERNHEIM"
, Christian Everdell
Cc:
Subject: FW: US V. Maxwell - 20 Cr. 330 (AJN) - Response to Government's Rule 17 Submission
Date: Thu, 13 May 2021 15:54:22 +0000
Attachments: 2021.05.12_JSP_Ltr_re_Response_to_Subpoena.pdf;_EX_A_.pdf; EX._B.pdf
Counsel,
In this filing, you represent that you have made multiple "attempts to confer with the government" regarding particular
photographs referenced in our May 6, 2021 letter on this issue, and you further represent that those attempts "have gone
unanswered for days." Our team is not aware of any communications we have received from you attempting to confer
about this particular issue between May 6, 2021 and May 12, 2021. Would you please either point us to the relevant
communication, or correct this representation to the Court?
Thank you,
Assistant United States Attorney
Southern District of New York
From: Laura Menninger
Sent: Wednesday, May 12, 2021 9:03 PM
To: Nathan NYSD Chambers
Cc: 'Bobbi Sternheim
is
Jeff Pagliuca
is
is
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Response to Government's Rule 17 Submission
Judge Nathan:
Attached please find Ms. Maxwell's Letter Response to the government's submission on the Rule 17 subpoena items 9-11,
and Exhibits A and B.
Because Exhibit B was a document marked "Confidential" by the government pursuant to the Protective Order, we are
compelled to file this under seal, pending any contrary order by the Court. We are prepared to file the Letter Response
and Exhibits on the public docket at the Court's direction.
Respectfully submitted,
EFTA00014669

=== Page 2 ===
Laura A. Menninger
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00014670


c1: EFTA00014290
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014290.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
N
(USANYS)"
)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE:
Data Transfer Issue
Date: Thu, 03 Jun 2021 17:31:35 +0000
We stamped "Confidential" on every page of the particular production
uploaded because it is a defined term in our
Court-ordered protective order. Per my conversation with
just now, I will send
a copy of one page of that
production (which consisted of 5GB of non-testifying witness 3500) along with our protective order, with the hopes that
we can head this off.
From:
(USANYS)
Sent: Thursday, June 3, 2021 12:15 PM
To:
(USANYS)
is
(USANYS)
is
)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
Subject: RE:
Data Transfer Issue
Security people have complained in the past that the rubric "confidential" should be reserved for classified
information, but "confidential" is in such common use in litigation and in protective orders that such a limitation
on its use never seemed workable. This is a little over the top, but that's what security is these days.
From:
(USANYS)
Sent: Thursday, June 3, 2021 12:06 PM
To:
(USANYS)
i
is
(USANYS)
is
(USANYS)
is
(USANYS)
i
(USANYS)
i
(USANYS)
Subject:
Data Transfer Issue
I am including everyone in this email because this situation has the potential to spin further out of control.
I just received a call from
,
the computer security chief at EOUSA. They have been continuing to look at this
situation. They have been reviewing the documents that were sent and have found documents that are stamped,
"CONFIDENTIAL". Such a stamping to them indicates the documents might be classified. He also said these documents
were not redacted and relate to Epstein. I told him they do relate to Epstein.
instructed me to have the Criminal
Chief or the AUSA contact the FBI to have them look at the documents and determine if they are classified. He wants this
done asap so that we can have a call later in the day with him and others, include the General Counsel's Office. He also
told me to notify the Contracting Officer on the this contract (she is at the Justice Management Division) and notify her of
a potential classified spill by a contractor. I told him I would do that if it is determined there was a classified spill.
EFTA00014290


c1: EFTA00016262
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016262.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
BOBBI C STERNHEIM
Cc: Christian Everdell
Subject: Re: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
Date: Fri, 29 Oct 2021 16:22:35 +0000
I am following up with the appropriate department.
BOBBI C STERNHEIM
10/29/2021 11:50 AM
Further my earlier email today, as of 10:30 a.m., USPO tracking lists
the following 4 items of legal mail
"Available for Pickup" and does not indicate that MDC has retrieved or
received them.
Ms. Maxwell has not received legal mail in more than a week.
Please confirm IMMEDIATELY the status of these items on your end.
Failure to response today will result in the filing of an order to show
cause requiring your presence in Court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim that may be confidential and/or
privileged.
If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank
you.
>
V
V
V
V
> Isabel Maxwell, Paralegal, Leah Saffian, Inc.
> LAW OFFICES OF LEAH SAFFIAN; LEAH SAFFIAN BA JD LLM
> 11420 SANTA MONICA BLVD #25424 LOS ANGELES, CA 90025, USA
V
EFTA00016262

=== Page 2 ===
>
> NOTICE: The information transmitted by this email is intended only
for the person or entity to which it is addressed. This email may
contain proprietary, business-confidential and/or legally privileged
material. If you are not the intended recipient of this message, be
aware that any use, review, retransmission, distribution, reproduction
or any action taken in reliance upon this message is strictly
prohibited. If you received this in error, please contact the sender
Isabel Maxwell at Tel
and delete the material from all
computers.
EFTA00016263


c1: EFTA00015716
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015716.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
)"
Subject: RE: travel approval request
Date: Tue, 22 Oct 2019 18:00:15 +0000
Approved for both and the conference room.
From:
Sent: Tuesday, October 22, 2019 1:55 PM
To:
Cc:
is
is
is
(
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
)
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
,
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
)
Sent: Friday, May 24, 2019 14:57
To:
>
Cc:
is
is
EFTA00015716

=== Page 2 ===
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
)
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
EFTA00015717

=== Page 3 ===
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00015718


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=== Page 1 ===
From: "
(FBI)"
To:
(USAFLS)"
"
Subject: Re: Epstein Investigation
Date: Fri, 04 Jul 2008 18:21:07 +0000
Importance: Normal
Hey happy 4th. FYI, I do not know that name, but I did just recv a call from
She does recall everything and said
took her
and she only went once. She said she was ashamed and uncomfortable. She is coming to FBI @ 930 Mon. We may want to met with
as
well.
Original Message
From:
(USAFLS)
To:
Sent: Fri Jul 04 11:24:41 2008
Subject: FW: Epstein Investigation
Hi guys - Have we ever heard of
(below)?
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From: Ted Leopold [mailto:
Sent: Thursday, July 03, 2008 4:25 PM
To:
(USAFLS)
Cc: Spencer Kuvin
Subject: RE: Epstein Investigation
Our two client names are:
1.
2.
EFTA00014156

=== Page 2 ===
if you need any other information please let me know.
Ted
Original Message
From:
(USAFLS) [mailto:
Sent: Monday, June 30, 2008 5:00 PM
To: Ted Leopold
Subject: Epstein Investigation
Dear Ted: Here is my e-mail address and contact information.
Thank you for your assistance.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014157


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=== Page 1 ===
From:
To:
Subject: Tentative: Call re Epstein FOIA case
Date: Fri, 04 Jun 2021 02:10:32 +0000
Importance: Normal
Attachments: unnamed
EFTA00016603


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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell
Date: Fri, 03 Jul 2020 17:21:45 +0000
- do you have a few minutes to talk this afternoon and, if so, what is the best number to reach you at?
Thanks,
From:
Sent: Thursday, July 2, 2020 4:51 PM
To:
Subject: RE: Ghislaine Maxwell
BOP is prepared to house her at MDC Brooklyn as early as next week. Would you be able to notify the SDNY USMS
accordingly?
Thank you,
>>>
>
7/2/2020 2:29 PM>>>
It sounds like she will remain at a local USMS-contracted facility for the holiday weekend. The USMS contact who reached
out to
Let me know if you learn otherwise, and/or keep
me apprised as plans develop in terms of where to situate here. Thanks,
From:
Sent: Thursday, July 2, 2020 2:05 PM
To:
Subject: RE: Ghislaine Maxwell
Any chance of a USMS facility through the holiday weekend while BOP officials decide how best to place her?
>>>
7/2/2020 2:02 PM >>>
Trying to figure that out. She is in a local facility in New Hampshire now, and will be presented virtually at 3:30. I would
assume she would then have to go immediately to a BOP or at least USMS-contracted facility.
From:
Sent: Thursday, July 2, 2020 1:50 PM
To:
Subject: Re: Ghislaine Maxwell
How soon do you expect her? With the holiday weekend quickly approaching, I would like to run things by my Regional
Counsel as well as our General Counsel in DC.
Thank you,
EFTA00016175

=== Page 2 ===
Deputy Regional Counsel
Northeast Regional Office
U.S. Customs House
2nd and Chestnut Streets
Philadelphia, PA 19106
=
>
7/2/2020 1:29 PM>>>
Hi
-
I hope you are doing well. I've recently taken on a new role as Counsel to the US Attorney. As you probably saw, Ghislaine
Maxwell was arrested today in New Hampshire. We expect her to consent to detention pending her transport to SDNY. I
was hoping to talk to the right person to ensure appropriate precautions are being taken for her safety, particularly given
the history here. Would that be you, or is there someone else I should connect with?
Thanks so much,
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00016176


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=== Page 1 ===
From:
To:
Subject: RE: Maxwell
Date: Thu, 02 Jul 2020 21:21:07 +0000
Thanks
From:
Sent: Thursday, July 2, 2020 10:48 AM
To:
Subject: FW: Maxwell
Big congrats! Very impressive you were able to bring this home. You guys are by far the most productive members of the
unit during quarantine.
From:
Sent: Thursday, July 2, 2020 10:43 AM
To:
Subject: Maxwell
PCU - Please join me in congratulating
on the arrest this morning of Ghislaine Maxwell.
spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't
repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges
were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and
perseverance and creativity by
in building a case based on conduct that I'm pretty sure is older
than all of our paralegals.
will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given
current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in
bringing an extremely important case against a woman very worthy of criminal prosecution.
EFTA00017735


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=== Page 1 ===
Case 9:08-cv-80119-KAM
Document 33
Entered on FLSD Docket 08/05/2008
Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 08-80119-CIV-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant.
/
ORDER DENYING MOTION TO STAY
THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay
(DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court
has carefully considered the motion and is otherwise fully advised in the premises.
Defendant Jeffrey Epstein ("Defendant") seeks a stay of this civil action under a federal
statute which reads, in pertinent part, as follows:
If, at any time that a cause of action for recovery of compensation for
damage or injury to the person of a child exists, a criminal action is
pending which arises out of the same occurrence and in which the child is
the victim, the civil action shall be stayed until the end of all phases of the
criminal action and any mention of the civil action during the criminal
proceeding is prohibited. As used in this subsection, a criminal action is
pending until its final adjudication in the trial court.
18 U.S.C. $ 3509 (k). In his motion, Defendant cites a state case, Florida V. Epstein, No. 2006
1
EFTA00014187

=== Page 2 ===
Case 9:08-cv-80119-KAM
Document
33
Entered on FLSD Docket 08/05/2008
Page 2 of 5
CF 09454AXX (Fla. Cir. Ct. 2008)¹ and a federal case, In re Grand Jury, No. FGJ 07-103(WPB)
(S.D. Fla.), that arise out of the same occurrences and are pending and thus require a stay of this
civil case. The federal "case," according to Defendant, involves a "deferred-prosecution"
agreement whereby the U.S. Attorney agreed to suspend its investigation of Defendant while
"retaining the right to reactivate the grand jury." (DE 24.) Defendant essentially reasons,
because the U.S. Attorney could bring criminal charges against Defendant, that a criminal action
is "pending." The Court rejects this definition of a "pending criminal action."
When interpreting the text of a statute, the Court begins with the plain meaning of the
text. In re Hedrick, 524 F.3d 1175, 1186 (11th Cir. 2008). If the plain meaning of a statute is
clear, the Court should not deviate from that interpretation. Id. Pending is defined as "remaining
undecided" and "awaiting decision." Blacks Law Dictionary (8th ed. 2004).² Likewise, an
¹As Defendant recognizes, the state court case was "finally adjudicated" and thus no
longer pending as of June 30, 2008. (See DE 12.)
2Defendant attempts to argue that the fact that grand jury subpoenas are still
"outstanding" and "not withdrawn" and that the grand jury will not be dismissed until Defendant
completes his obligations under the state plea agreement means that a "criminal action" is
"pending." (Def. Reply 4.) Defendant misunderstands the purpose of a grand jury. A grand
jury, as Blackstone writes, is composed of citizens who "inquire, upon their oaths, whether there
be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers V.
Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand
jury's sole purpose is to inquire into whether there is probable cause to bring an individual before
a tribunal to determine his guilt or innocence of an alleged crime. Id. The grand jury is simply
an investigative body. See U.S. V. Alred, 144, F.3d 1405, 1413 (11th Cir. 1998). A "criminal
action" is not instigated by the calling of a grand jury, because a grand jury is convened "to
determine whether a crime has been committed and whether criminal proceedings should be
instituted against any person." U.S. V. Calandra, 414 U.S. 338, 344 (1974). An "action" is
commenced against a person after the grand jury actually finds probable cause to make an
individual answer specific charges and renders a bill of indictment against that individual. Until
a grand jury's investigation is complete and there has been a determination by a lawful authority
that probable cause exists, there can be no criminal action.
2
EFTA00014188

=== Page 3 ===
Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 3 of 5
"action" is defined as a "criminal judicial proceeding." Id. Because the U.S. Attorney has not
filed an indictment or an information against Defendant, the Court fails to see how there is an
undecided judicial proceeding in federal court against Defendant.
Defendant argues that this statute should be read to include the definition of "criminal
action" used in 18 U.S.C. § 1595(b)(2), which reads as follows: "In this subsection, a "criminal
action' includes investigation and prosecution and is pending until final adjudication in the trial
court." Defendant argues that "Congress specifically intended that the term "criminal action'
would be applied extremely broadly" under $ 1595, so Congress "took pains to ensure that courts
would give it the broadest possible construction" and defined "criminal action" as including
investigatory stages. (Def. Reply 4.) Defendants argue that the Court should borrow this
definition.
The Court disagrees. The Court believes that Congress's inclusion of this broader
definition under § 1595 evinces Congressional intent to depart from the normal meaning of the
term "criminal action."3 This addition to the text suggests that Congress knows the plain
meaning of the term "criminal action" and that Congress decided, under $ 1595, that the
definition of "criminal action" should be broader. In contrast, Congress could have made such an
addition to § 3509 had it intended the mandatory stay provision to apply to pre-indictment
investigations, but it did not. In other words, by not broadening the definition of "criminal
action" $ 3509, Congress intended that the term should only have its ordinary meaning: that an
indictment or information has been filed naming a specific defendant. Instead, it seems clear that
3In fact, Congress made this intent clear by stating that this broader definition of a
"criminal action" applied only "in this subsection."
3
EFTA00014189

=== Page 4 ===
Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 4 of 5
Congress intended that these two statutory provisions should each have a different scope.
Defendant's argument of statutory construction fails.
The single case cited by Defendant in support of his motion is not on point. In Doe 1 V.
Francis, No. 5:03CV260/MCR/WCS, 2005 WL 517847 (N.D. Fla. Feb. 10, 2005), the stay was
entered because criminal charges had been filed against the defendant in a state court several
months earlier (i.e., the defendants had been indicted by the state attorney). See Memorandum in
Support of Motion to Stay Proceedings Pending Outcome of Parallel Criminal Proceedings at 3,
Doe 1 V. Francis, No. 5:03CV260/MCR/WCS (N.D. Fla. Dec. 2, 2003). The Court agrees with
Defendant that a stay under § 3509(k) is mandatory when a criminal action is pending; the Court
simply disagrees that the "deferred-prosecution agreement" constitutes a pending criminal action.
The Court also does not believe a discretionary stay is warranted. Defendant did not seek
this relief in his motion; including such a request in the reply brief is inappropriate. Further, the
Court sees no reason to delay this litigation for the next thirty-three months. After all, Defendant
is in control of his own destiny - it is up to him (and him alone) whether the plea agreement
reached with the State of Florida is breached. If Defendant does not breach the agreement, then
he should have no concerns regarding his Fifth Amendment right against self-incrimination. The
fact that the U.S. Attorney (or other law enforcement officials) may object to some discovery in
these civil cases is not, in an of itself, a reason to stay the civil action. Any such issues shall be
resolved as they arise in the course of this litigation.
Accordingly, it is ORDERED AND ADJUDGED as follows:
1. Defendant's Motion to Stay (DE 12) is DENIED.
2. Defendant's Motion for Hearing (DE 27) is DENIED AS MOOT.
4
EFTA00014190

=== Page 5 ===
Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 5 of 5
3. Plaintiff's Motion for an Extension of Time to File Response (DE 18) is GRANTED NUNC
PRO TUNC.
DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County,
Florida, this 4th day of August, 2008.
Kn
KENNETH A. MARRA
United States District Judge
Copies furnished to:
all counsel of record
5
EFTA00014191


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=== Page 1 ===
Forwarded message
From:
Date: Tue, Jun 29, 2010 at 8:33 AM
Subject: Jeffrey Epstein
To:
Hello
Jeffrey looks forward to seeing you on Wed. July 8th at 5:00 at his
home. He lives at:
9 East 71ˢᵗ Street between 5th and Madison.
I will re-confirm with you on the 8th
Take care and safe trip here!
EFTA00015060

=== Page 2 ===
Tel:
EFTA00015061


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=== Page 1 ===
From: STACEY RICHMAN <srichmanlaw@msn.com>
To:
Subject: Fw: Then #10
Date: Mon, 25 May 2020 17:09:42 +0000
Inline-Images: IMG_1292.JPG
STACEY RICHMAN
Law Offices of
Richman Hill & Associates PLLC
2027 Williamsbridge Road
Bronx, New York 10461
(718) 892-8588 (Main)
(718) 518-0674 (Facsimile)
***Confidentiality Notice***
This email and any accompanying documents contains information that is intended only for the use of the
individual or entity to whom it is addressed and may contain information that is legally privileged, confidential
or otherwise exempt from disclosure under applicable laws. If the reader of this message is not the recipient, any
disclosure, dissemination, distribution, copying, or other use or retention of this communication or its substance
is prohibited. If you have received this email in error, please delete it and notify the sender by return email.
Thank you.
From: Mark L. Epstein <izmo@mindspring.com>
Sent: Sunday, May 24, 2020 6:47 PM
To: STACEY RICHMAN <srichmanlaw@msn.com>
Subject: Then
EFTA00016966

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


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=== Page 1 ===
From: "DiPiero, Joseph"
To:
)"
Cc: "Moyne, Parvin"
"Benjamin, James"
)"
,
>, , "Moyer, Thomas"
Subject: Deutsche Bank Production
Date: Fri, 13 Dec 2019 20:18:52 +0000
Attachments: 2019.12.13 - _DB_Submission_to_SDNY.pdf; 2019.12.13 - Appendix_A.xlsx
On behalf of our client, Deutsche Bank, the link below contains an additional production of documents in response to
your July 11, 2019 subpoena. Also attached is the accompanying cover letter for today's production, as well as an
updated version of the production index we previously provided. I will send the password shortly under separate cover.
Please do not hesitate to reach out if you have any questions.
Regards,
Joey
Production Link:
Joseph T. DiPiero
AKIN GUMP STRAUSS HAUER & FELD LLP
2001 K Street N.W.
|
Washington, DC 20006
USA
Direc
Fax: +1 202.887.4288
I
|
akingump.com
Bio
Licensed to practice in West Virginia only and under the supervision of the partners of Akin Gump Strauss Hauer & Feld LLP. Application for admission to
the District of Columbia Bar pending.
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.
EFTA00016397


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=== Page 1 ===
From:
To:
Subject: Re: out of curiosity
Date: Thu, 09 Apr 2020 14:26:06 +0000
Nothing really to report for my cases. They're pretty hands on when it comes to
et al, but nothing like you're
describing (or
has seemingly experienced with AMI).
From:
Sent: Thursday, April 9, 2020 10:12 AM
To:
Subject: out of curiosity
To the extent anybody in this small group is willing to share, are any of you folks' teams / cases getting significant pressure
from the chiefs on memos or other written product this week, whether for the brass or otherwise? I'm just curious
whether it's just the Epstein case (where we're getting near-daily prodding about imminent deadlines for memos that are
both extremely time-intensive and also couldn't possibly be acted upon for weeks, given the circumstances of the world)
or if it's something broader in the unit. I just sent the chiefs a pretty crabby email about being bugged daily about lengthy,
detailed work product and it made me wonder whether this is a trend or an isolated incident.
More importantly, hope y'all and families are all staying healthy
Assistant U.S. Attorney
Southern District of New York
EFTA00015282


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=== Page 1 ===
From:
To:
>,
Cc:
>
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
Date: Mon, 13 Jul 2020 23:28:37 +0000
Good evening,
As discussed, I have run this up my chain, and BOP would prefer not to comment on Ms. Maxwell's housing conditions in
public filings.
Thank you!
>>>
)" <
>
7/12/2020 4:17 PM >>>
Thanks,
On a separate subject, is it correct that, for security reasons, the defendant is being housed in her own cell
(without a cellmate), and that her exercise time is separate from other inmates? That is our current understanding, but we
wanted to confirm, and also to make sure the BOP would not have an issue if we referenced this in public filings.
Thanks,
From:
Sent: Sunday, July 12, 2020 4:13 PM
To:
Cc:
is
is
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
Thanks for the update, and totally understand it's over a weekend, and we did not know that defense counsel had also
been having additional afternoon calls, so that's helpful to know. Also helpful to know that you have not received other
calls or emails from counsel. We'll let her counsel know that they will have calls tomorrow and Tuesday at 10:00 a.m., and
thanks very much again for your help.
From:
Sent: Sunday, July 12, 2020 15:28
To:
Cc:
is
>;
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Apologies all, I just saw these emails. We are not providing weekend calls generally at this time, and counsel has been having
2 hour legal calls every afternoon in addition to the standing call set up in the morning. This is far more than almost every
EFTA00015957

=== Page 2 ===
other inmate receives prior to an arraignment. Most other arraignments have been set up with one or two days notice, with
only one call to counsel and one call to pretrial services.
I have received no calls or emails from counsel, so I'm not sure where they have made these emergency requests.
They will have another call with her tomorrow, and I can let staff know they will request the call on Tuesday as well.
>>>
)"
>
7/12/2020 12:42 PM >>>
Following up, we heard from defense counsel that they didn't receive a call this morning either and that they filed an
emergency request but haven't heard back. Please let us know the status as soon as possible? They also wanted to confirm
that they will have calls at 10:00 tomorrow and Tuesday. Again, we realize this is unusual but I'm not aware of any other
defendants who are in this circumstance of having a bail hearing pending in just two days. Also copying
in case he's
aware of someone else we should contact.
thank you,
On Jul 12, 2020, at 09:24,
)
<
> wrote:
Following up on this - we understand that as of Tuesday defense counsel will go through the normal process, but since
the client's bail hearing is Tuesday they did anticipate being able to speak with her this weekend and tomorrow in advance.
Thanks again and sorry for the bother.
On Jul 11, 2020, at 17:16,
<
wrote:
We just were contacted by defense counsel, who said they didn't have a call with their client this morning - I think they
expected that the morning calls up until her arraignment on Tuesday would include the weekend. Is it possible to
reinstitute the call for tomorrow at 10:00, as well as on Monday? Thanks very much, and sorry for the late notice - we
just heard from them a moment ago.
thanks,
From:
Sent: Friday, July 10, 2020 10:34
To:
Cc:
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Great - thank you again! (I told defense counsel that I would ask, but also just to give it a few minutes
.)
Sent from my iPhone
On Jul 10, 2020, at 10:30,
wrote:
I've been informed she is on the phone
)"
7/10/2020 10:26 AM >>>
EFTA00015958

=== Page 3 ===
Defense counsel for Maxwell communicated to us a few minutes ago that they haven't gotten a call yet this morning.
Do you know if that has gone through in the past five or ten minutes? They are looking to speak with her before her
interview with pretrial this afternoon.
I'm reachable at
if it's useful to chat in real time.
thanks,
On Jul 7, 2020, at 19:50,
wrote:
,
You're welcome. We will do our best to provide a call at 10:00 AM every day this week to Mr. Everdell at
the number he has previously provided. We will also provide a call on Monday 7/13/20.
The EDNY and SDNY created a joint protocol whereby counsel may request legal calls to be placed in the
afternoon at the MDC. Requests should be sent to
Truly urgent requests can be sent to me, but unless there is a last minute, imminent court deadline, counsel
really should send the requests to the federal defenders, as outlined in the protocol. We want to ensure
inmates get equitable access. If they anticipate needing several calls in a week, they should make requests in
advance and note whether and when calls would be preferred. Generally, calls are for 30 minutes in
duration. If a longer call is desired, that should be explained as well.
If you need anything else, please let me know.
Thank you,
)"
7/7/2020 5:00 PM
Thank you so much,
A 10am standing legal call every day before the arraignment on Tuesday 7/14 would be perfect if that's something
you would be able to accommodate. Defense counsel will be available at that time, and they are very grateful for
the time.
We have also conveyed to defense counsel that they will need to follow the same protocols as other inmates'
counsel following the arraignment. Thank you for letting us know about the lack of requests from defense counsel
thus far. There appears to be some confusion on their end about how to submit requests to schedule legal calls.
Would you be able to please share with us the procedure that they should follow, so that we can make sure they
understand what steps to take going forward?
Thank you again for all of your help-we really appreciate it.
Best,
From:
Sent: Tuesday, July 7, 2020 4:23 PM
To:
Cc:
is
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
You're welcome.
Would 10 am work as a standing legal call through the end of this week (and Monday, if you think that's a good idea),
in advance of the arraignment on Tuesday? However, after this, defense counsel should be required to follow the same
protocols as all other inmates' counsel with respect to requesting legal calls.
I also just want to make clear that defense counsel sent no requests yesterday that I am aware of, and we were able to
facilitate a call yesterday evening following a request from your office, and today, I received one request, about mid-
day, that we were again able to accommodate. So, I do not think it is fair at all to categorize this as defense counsel
having difficulty scheduling legal calls.
Thank you,
EFTA00015959

=== Page 4 ===
>>>
)"
> 7/7/2020 2:37 PM >>>
Thanks,
This is about the legal call today. In addition, because defense counsel his having difficulty scheduling
legal calls, it would be helpful if MDC could schedule standing calls for the rest of this week to address this issue.
Thanks very much.
From:
Sent: Tuesday, July 7, 2020 2:36 PM
To:
Cc:
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Hi
I just saw this now. Is this about the legal call issue or something separate? If it's about the legal call, I am working on
it.
Thanks,
>>>
)"
> 7/7/2020 1:27 PM >>>
Hi
Thanks for your help with this. Are you available now for a call? We are having a time sensitive issue with this.
Thanks,
Sent from my iPhone
On Jul 6, 2020, at 7:59 PM,
<
> wrote:
Hi
For future reference, there is a protocol in place for defense counsel to reques legal calls. If counsel is unaware of it, I
can provide the details.
However, I understand that she just came into custody today and there is a more urgent deadline. If you can please
provide the name and phone number of counsel, I will do my best.
Thanks,
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
Date: 7/6/20 7:48 PM (GMT-05:00)
To:
>
Cc:
>,
>
Subject: Ghislaine Maxwell (USMS No. 02879-509)
>>>
)" 07/06/2020 19:48 >>>
Hi
Hope you're doing well. This evening, Judge Nathan directed the parties in the US V. Ghislaine Maxwell case to file
a letter by 9pm today. Defense counsel need to speak with Ms. Maxwell this evening about the letter, but they
have not been able to reach her. Would it be possible to allow Ms. Maxwell to make a legal call to her lawyers this
evening, please?
Thank you very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015960


c1: EFTA00015525
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015525.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Call with FBI (Epstein)
Date: Mon, 24 Jun 2019 22:35:38 +0000
Importance: Normal
Attachments: unnamed
EFTA00015525


c1: EFTA00016893
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016893.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Arlan Ettinger
Date: Fri, 17 Jan 2020 18:59:27 +0000
I never handled anything like this before. Perhaps,
might know. Should I forward to him?
From:
Sent: Friday, January 17, 2020 1:55 PM
To:
Subject: FW: Arlan Ettinger
Do you have a record of how we handled this?
From:
Sent: Wednesday, January 15, 2020 4:42 PM
To:
Subject: FW: Arlan Ettinger
Good afternoon,
I wanted to follow-up on the below correspondence. As part of the close-out process Exec Sec are requesting comments
from USAO-SDNY. Could you please provide me with your district's response?
Thank you very much in advance for your consideration of this matter,
From:
Sent: Wednesday, October 9, 2019 1:57 PM
To:
Subject: Arlan Ettinger
Good afternoon!
I have been advised to forward you the attached correspondence from Arlan Ettinger, President of Guernsey's Auctioneers
& Brokers. The letter is regarding the property of the late Jeffrey Epstein. As advised by Nathaniel Gamble II from ODAG
(see email attached), this has been assigned to USAO-SDNY for handling. Please let me know if you have any questions or
concerns.
Thank you very much in advance.
Best,
U.S. Department of Justice
EFTA00016893

=== Page 2 ===
Executive Office for U.S. Attorneys
O:
Pronouns: she/ her/ hers
EFTA00016894


c1: EFTA00015632
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015632.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Fwd: Epstein
Date: Thu, 11 Jul 2019 13:47:47 +0000
Importance: Normal
Nothing on today, right?
Sent from my iPhone
Begin forwarded message:
From: Juliet Papa <papa@wins.com>
Date: July 11, 2019 at 9:38:53 AM EDT
To:
Subject: Re: Epstein
Thank you for confirming. I told my desk that and they were insisting he had a court appearance. Either they
are reading something incorrectly or wires have it wrong.
Juliet Papa
Reporter
1010 WINS Radio
1010WINS.com
Entercom
Twitter: @winsjuliet
Sent from my iPhone
On Jul 11, 2019, at 8:45 AM,
wrote:
Nope. Monday at 10:00 am, Judge Berman. The defense brief is due today and our response is due tomorrow.
Sent from my iPhone
On Jul 11, 2019, at 8:12 AM, Juliet Papa <papa@wins.com> wrote:
Hi
-does he have a court appearance today? Thanks-
Juliet Papa
EFTA00015632

=== Page 2 ===
Reporter
1010 WINS Radio
1010WINS.com
Entercom
Twitter: @winsjuliet
Sent from my iPhone
EFTA00015633


c1: EFTA00017749
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017749.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Arlan Ettinger
Date: Wed, 29 Jan 2020 14:36:42 +0000
Dear
We viewed this as an ad, asking that the vendor to be considered to sell services to us and not requiring any response by
DOJ or us. Therefore, we did not respond.
Please let me know if you have any questions or see any need for any follow up.
Regards,
From:
Sent: Wednesday, January 15, 2020 4:42 PM
To:
Subject: FW: Arlan Ettinger
Good afternoon,
I wanted to follow-up on the below correspondence. As part of the close-out process Exec Sec are requesting comments
from USAO-SDNY. Could you please provide me with your district's response?
Thank you very much in advance for your consideration of this matter,
From:
)
Sent: Wednesday, October 9, 2019 1:57 PM
To:
Subject: Arlan Ettinger
Good afternoon!
I have been advised to forward you the attached correspondence from Arlan Ettinger, President of Guernsey's Auctioneers
& Brokers. The letter is regarding the property of the late Jeffrey Epstein. As advised by Nathaniel Gamble Il from ODAG
(see email attached), this has been assigned to USAO-SDNY for handling. Please let me know if you have any questions or
concerns.
Thank you very much in advance.
Best,
U.S. Department of Justice
Executive Office for U.S. Attorneys
EFTA00017749

=== Page 2 ===
O:
Pronouns: she/ her/ hers
EFTA00017750


c1: EFTA00016437
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016437.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search warrant documents
Date: Fri, 15 May 2020 19:30:04 +0000
Okay thanks, just wanted to make sure given that column. If you could please confirm with him as he starts to send us
stuff, that would be great - we'll basically just want to re-load all that stuff (which, separately, also got uploaded to the
wrong folder structure in Relativity so we can circle up on that whenever you get the new info too). Thanks.
From:
Sent: Friday, May 15, 2020 15:28
To:
Cc:
is
Subject: RE: Epstein search warrant documents
I mentioned to
that the only first delivery we were able to upload to the database and told him the issues with the
other two deliveries. I believed that he understands that he needs to replace those deliveries that we could not use.
From:
Sent: Friday, May 15, 2020 3:25 PM
To:
Cc:
is
Subject: FW: Epstein search warrant documents
Following up on our discussions, I think this actually looks fairly useful. The only thing I wanted to highlight to you is that
based on this spreadsheet, it seems to say that only five devices from NY have materials that are still outstanding to be
transferred to us (looking at the "Remaining to be transferred" column). Just based on what we've gotten so far, I find
that difficult to understand (since we have so few overall docs), but even assuming that's right, *anything* in the prior
two transfers to us (one hard drive that we did upload, that was all screwed up for the reasons you previously identified,
and one hard drive that we didn't upload for the same reasons) needs to be re-transferred based on the format you and
have discussed, right?
I just want to make sure he doesn't only transfer what he views as "remaining," leaving us with like 95% of the material
being in a form that's not useful for us. And figured I'd check with you to see if that's your understanding with him before
replying all to clarify.
thank you!
From:
Sent: Thursday, May 14, 2020 15:54
To:
is
Cc:
is
is
EFTA00016437

=== Page 2 ===
is
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
is
Cc:
is
is
is
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:
Sent: Tuesday, May 12, 2020 13:03
To:
is
EFTA00016438

=== Page 3 ===
Cc:
is
is
is
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
Sent: Tuesday, May 12, 2020 11:30
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
EFTA00016439

=== Page 4 ===
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
Sent: Tuesday, May 12, 2020 11:11
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
Subject: RE: Epstein search warrant documents
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.
EFTA00016440

=== Page 5 ===
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
>;
i
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
)
>;
V.
(USANYS)
Cc:
in
is
is
is
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
)
is
is
(USANYS)
Cc:
is
is
i
is
EFTA00016441

=== Page 6 ===
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
Sent: Tuesday, April 07, 2020 15:27
To:
>;
(USANYS)
is
is
(USANYS)
Cc:
is
is
>;
i
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
is
is
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.
EFTA00016442

=== Page 7 ===
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
is
is
(USANYS)
Cc:
is
>;
i
is
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
i
is
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
EFTA00016443

=== Page 8 ===
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
V.
(USANYS)
Cc:
is
is
i
is
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
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.
EFTA00016444

=== Page 9 ===
(office)
(cell)
From:
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
>;
is
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
V.
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
)
is
is
is
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
EFTA00016445

=== Page 10 ===
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:
>;
>;
i
i
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
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.
EFTA00016446

=== Page 11 ===
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00016447


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=== Page 1 ===
WARRANTY DEED
THIS INDENTURE made the 18th day of January, 2016 between Christian Kjaer
a/k/a Poul Christian Tage Kjaer, c/o Kevin F. D'Amour, 5143 Palm Passage, Suites 18B and 19B. St.
Thomas. USVI 00802. (hereinafter the "Grantor") and Great St. Jim, LLC. a Virgin Islands Limited
Liability Company. c/o Kellerhals Ferguson Kroblin PLLC, Royal Palms Professional Building. 9053
Estate Thomas, Suite 101. St. Thomas, VI 00802 (hereinafter referred to as "Grantee").
WITNESSETH: That the Grantor, for and in consideration of the sum of SEVENTEEN
MILLION FIVE HUNDRED THOUSAND and 00/100 DOLLARS ($17,500,000.00). paid by the
Grantee. the receipt of which is hereby acknowledged. and other good and valuable consideration, does
hereby grant and convey unto the Grantee. its successors and assigns, in fee simple absolute forever. all of
his right. title and interest in and to the following described real property.
Parcel A Rem Great St. James Island
Dear
Parcel A-1 Great St. James Island
No. 6A Red Hook Quarter
No. 6A Red Hook Quarter
St. Thomas, Virgin Islands
St. Thomas, Virgin Islands
As shown on PWD No. A9-626-T004
As shown on PWD No. A9-626-T004
Consisting of 56.1 U.S. Acres more or less
Consisting of 4.2 U.S. Acres more or less
40
arcel A-2 Great St. James Island
No. 6A Red Hook Quarter
St. Thomas, Virgin Islands
As shown on PWD No. A9-626-T004
Consisting of 19.8 U.S. Acres more or less
BEING THE SAME PREMISES which was conveyed to the Grantor by Final
Adjudication of the Estate of Karen Elisabeth Kjaer a/k/a Karin Lis Kjaer dated October 15. 1987,
recorded at the office of the Recorder of Deeds for St. Thomas and St. John on October 21. 1987. in Book
No. 31-D. Page 54, Doc. No. 5090.
TOGETHER WITH any improvements thereon, and the rights, privileges and
appurtenances belonging thereto;
Book:
Pages: 0000
Doc# 2016000575
Filed & Recorded
Doc# 2016000575
01/28/2016 2:50PM
ERICA DOVER, M.P.A.
RECORDER OF DEEDS
ST THOMAS/ST JOHN
RECORDING FEE
$ 17,512.00
DEED DOC STAMP 3.5
$ 612,500.00
PER PAGE FEE
$
5.00 |
ATTACHMNT FEE
$
4.00
EFTA00014362

=== Page 2 ===
027135
TO HAVE AND TO HOLD the premises conveyed hereby unto the Grantee, its
successors and assigns. in fee simple absolute forever.
SUBJECT, HOWEVER. to Virgin Islands zoning regulations and to the
covenants restrictions. easements and agreements of record.
AND THE GRANTOR WARRANTS that he is seized of the premises in fee
simple and that he has good right to convey the premises, that Grantee shall quietly enjoy the
premises: that the premises are free from encumbrances except as set forth or referred to herein:
that Grantor will execute or procure any further necessary assurances of title to the premises and
that Grantor will forever warrant and defend title to the premises.
IN WITNESS WHEREOF. the Grantor has executed this warranty deed the day
and year first above written.
WITNESS:
Christian Kjaer A/K/A Poul Christian Tage Kjae:
KINGDOM OF DENMARK
) SS.
This is to certify that Christian Kjaer today on my presence at the Notarial Office approved and
signed the above document. No conspicuous corrects or addenda were found in the document.
He has proved his identity by presenting his passport.
District Court of
, Denmark the
day of January, 2016.
Notary Public
00 Doc#
2
EFTA00014363

=== Page 3 ===
NOTED IN THE CADASTRAL RECORDS
FOR COUNTRY / TOWN PROPERTY, BOOK FOR
GREAT ST. JAMES ISLAND
NO. 6A RED HOOK QUARTER
ST. THOMAS VIRGIN ISLANDS
Tax Assessor Office / Cadastral Division
St. Thomas, V.I. Dated: HANUARY 21, 2016
Wayne D. Callwood
I
cell the Lieutenant Governor / Public Surveyor
ATTEST:
"is hereby certified that the above mentioned
property/s which, according
to WARRANTY DEED dated January 21,2016
belongs to: GREAT ST.JIM, LLC a Virgin Islands Limited Liability Company (GRANTEE)
has not according to the Record of this office,
undergone changes as to boundaries and area.
Tax Assessor Office / Cadastral Division
St. Thomas Datedin JANUARY 21, 2016
:
Wayne Callwood
Office of the Lieutenant Governor / Public Surveyor
EFTA00014364

=== Page 4 ===
RETTEN LYNGBY
027135
This is to certify that
DANMARKS DOMSTOLE
Mr. Poul Christian Tage Kjær
today in my presence at the Notarial Office approved and signed the above
document.
No conspicuous corrections or addenda were found in the document.
Mr. Poul Christian Tage Kjær has proved his identity by showing drivers
licens.
The Court in Lyngby, Denmark, 18 th January 2016
Ann-Kathrine Meyer Gravgaard
Notary D Public
RETTEN I LYNGBY
DANMARKS DOMSTOLE publícus
Doc# 00
EFTA00014365

=== Page 5 ===
COMMISSION OF THE
UNITED
GOVERNMENT OF
THE UNITED STATES VIRGIN ISLANDS
OFFICE OF THE LIEUTENANT GOVERNOR
DIVISION OF REAL PROPERTY TAX
1105 King Street Christiansted, Virgin Islands 00820 340.773.6449
Fax
340.773.0330
18 Kongens Gade Charlotte Amalle, Virgin Islands 00802 . 340.774.2991 Fax 340.774.6953
REAL PROPERTY TAX CLEARANCE LETTER
TO:
Recorder Of Deeds
FROM: Office of the Tax Collector
In accordance with Title 28, Section 121, as amended, this shall certify that
there are no outstanding Real Property Tax obligations for the following:
PARCEL NUMBER
1-09801-0101-00
GREAT ST JAMES ISLAND
LEGAL DESCRIPTION
RED HOOK QTR.
OWNER'S NAME
KJAER, CHRISTIAN
Taxes have been researched up to and including
2015
-
CERTIFIED TRUE AND CORRECT BY
LUDENCE ROMNEY
TAX COLLECTOR
Li A.F.
SIGNATURE
Doc# 2016000575
01/11/2016
DATE
EFTA00014366


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Epstein / Maxwell Case
Date: Mon, 13 Jul 2020 17:14:35 +0000
I would like to acknowledge her email if you let me.
From:
Sent: Monday, July 13, 2020 1:03 PM
To:
Subject: Epstein / Maxwell Case
Hello,
I've debated whether to send this email a thousand times. In fact, I've written it numerous times. Hopefully I
will be brave enough to send it this time.
My name is
I was sexually assaulted when I was barely 18 years old in a NYC
restaurant / club. At the time, I was too scared and confused and well traumatized to do anything about it. My
life pretty much crumbled after that. And by the time I pulled myself together, it was too late to do anything
about it. Or at least I felt it was. I had done such a good job, eradicating anything associated with that part of
my life and scrubbing my mind of the memories that I no longer remembered the details like the name of the girl
that invited me along and introduced me to the person who assaulted me as well as the name or location of the
venue. So I did nothing
A few months ago, I saw Epstein's face on the news and I put everything altogether... I was sexually assaulted by
Jeffery Epstein.
He's dead now. so I'm not really sure why I'm emailing or even bringing it up now but I just felt like I should let
someone know. If I can be of help in anyway, I'd like to be. However, I don't really have proof and I can't really
offer anything as far as Maxwell's case goes. She could have been there as well as I do remember there being a
"woman" there along with numerous other "girls". I remember making a mental note to myself how it was weird
that there that I was probably the oldest one out of the girls that were there except for the one woman that was
sitting with the other men.
Anyway, for now, I'd prefer to talk via email but if it makes sense, I'd be okay chatting with you in the future if
you think it makes sense. Again, I'm not sure if I can be of any help or if it even makes sense to reach out
anymore. but I just felt like I'd never forgive myself if I stayed silent again this time.
Thank you.
Sincerely,
EFTA00015950


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=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
(USANYS)"
(USANYS)"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject:
Date: Tue, 08 Oct 2019 17:02:59 +0000
Apparently just completed a conference call with the media. In the call, she stated that the FBI has located Ghislaine
Maxwell and an arrest and/or charges are imminent (citing a looming statutory deadline).
She also stated that two meetings with law enforcement have been held with victims, one in NYC
and one in Florida.
Nicholas Biase
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
EFTA00015285


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=== Page 1 ===
From:
To:
Subject: Necheles Submission
Date: Mon, 20 Jul 2020 16:08:38 +0000
Attachments:
plea_submission,_with_attachments.pdf
Attached
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00015192


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 345 Filed 10/14/21 Page 1 of 3
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
HADDON
MORGAN
150 East 10th Avenue
FOREMAN
Denver, Colorado 80203
PH
www.hmflaw.com
October 14, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Deadline for Filing Motion under Federal Rule of Evidence 412,
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write to confirm that November 15, 2021 is the deadline for Ms. Maxwell to file a
motion under Federal Rule of Evidence 412, which governs the admissibility of evidence of an
alleged victim's sexual behavior.
Under this Court's pretrial scheduling order, motions in limine are due on October 18. A
motion in limine is a "pretrial request that certain inadmissible evidence not be referred to or
offered at trial." Black's Law Dictionary (11th ed. 2019).
A motion under Rule 412 is not a motion in limine. Rather, it is a motion seeking
permission to admit evidence the Rules of Evidence might otherwise exclude. It is a substantive
motion under a specific rule of evidence with specific procedures for its filing, consideration, and
determination. Fed. R. Evid. 412(c). And the Rule itself sets a deadline for filing a motion under
its terms-14 days before trial. Fed. R. Evid. 412(c)(1)(B) (providing that a defendant must file
her motion "at least 14 days before trial unless the court, for good cause, sets a different time").
EFTA00016720

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 345 Filed 10/14/21 Page 2 of 3
The Honorable Alison J. Nathan
October 14, 2021
Page 2
Ms. Maxwell's counsel conferred with the government about the timing for filing a
motion under Rule 412. The government seeks to have the motion briefed before jury selection
begins.
Implicit in the language of Rule 412(c)(1)(B) is authority for the Court to permit a
defendant to file a motion closer to trial than 14 days, for good cause. But contrary to the
government's suggestion, the Rule does not contemplate a deadline more than 14 days before
trial.¹
In any event, Ms. Maxwell should not be required to file her Rule 412 motion any time
before November 15, since it was just three days ago (October 11) that the government disclosed
its 3500 material, including more than 8,000 pages of testifying witness disclosures. It will
require significant time and resources to review and investigate this material and to identify any
potentially admissible Rule 412 evidence.
It was also just three days ago that the government alerted defense counsel to its
anticipated Rule 404(b) witnesses. Rule 412's procedures apply not just to alleged victims named
in the indictment but to any alleged victim in a case involving sexual misconduct, including
alleged 404(b) victims. Fed. R. Evid. 412, Advisory Committee Notes, 1994 Amendments
("Rule 412 extends to 'pattern' witnesses in both criminal and civil cases about other instances
of sexual misconduct by the person accused is otherwise admissible.").
Finally, Ms. Maxwell (who is in custody) was only provided a copy of the government's
disclosures earlier today in the late morning. Until Ms. Maxwell is able to review the material,
1 See Fed. R. Evid. 412, Advisory Committee Notes, 1994 Amendments, Subdivision (c)
("The requirement of a motion before trial is continued in the amended rule, as is the provision
that a late motion may be permitted for good cause shown." (emphasis added)).
EFTA00016721

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 345 Filed 10/14/21 Page 3 of 3
The Honorable Alison J. Nathan
October 14, 2021
Page 3
her counsel cannot adequately consult with her about the defense. Allowing Ms. Maxwell to file
her Rule 412 motion 14 days before trial, as the Rule itself provides, is essential for counsel to
effectively consult with Ms. Maxwell, to investigate and research what evidence they will seek to
admit under Rule 412, as well as to comply with the several procedural steps required by the
Rule.
Accordingly, unless this Court orders otherwise, Ms. Maxwell will file her Rule 412
motion on or before November 15, 2021, as provided in Rule 412(c)(1)(B).
Respectfully Submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
)"
Subject: Re: Random Epstein Question
Date: Sun, 12 Apr 2020 14:37:20 +0000
Not that we're aware of.
On Apr 12, 2020, at 09:38,
(USANYS) [Contractor]
wrote:
Good morning everyone, I hope you guys are hanging in there.
Random question for you (from
): Were there any interrogatories answered by Maxwell in the
lawsuit?
I did a quick look through the shared and didn't see anything, but obviously you all would know better.
Thanks in advance!
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From:
To:
Cc:
Subject: Expedia subpoena
Date: Fri, 24 Jan 2020 17:10:11 +0000
Attachments: 2020-01-24,_subpoena_to_Expedia.pdf
Please also serve the attached subpoena to Expedia, relating to Maxwell travel.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York. NY 10007
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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
Date: Mon, 19 Aug 2019 18:20:11 +0000
Attachments:
Time: Aug 19, 2019 2:20:11 PM
Click attachment to listen to Voice Message
EFTA00015698


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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Thu, 27 Jun 2019 20:31:09 +0000
Importance: Normal
Are Victims 2, 3, and 4 on the list?
From:
Sent: Thursday, June 27, 2019 4:30 PM
To:
Subject: RE: Epstein
32
From:
Sent: Thursday, June 27, 2019 4:30 PM
To:
Subject: RE: Epstein
Great. Thanks. How many names are on the list?
From:
Sent: Thursday, June 27, 2019 4:29 PM
To:
Cc:
Subject: Epstein
We obtained the list of victims in the side-letter to the NPA, and confirmed that our principal NY victim is not on it - it
appears that all the victims are Florida.
Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
t.
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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Wednesday
Date: Tue, 30 Jul 2019 20:38:00 +0000
Inline-Images: image001.jpg; image002.png; image003.jpg; image004.png; image005.jpg
I was referring to my hotel.
From:
Sent: Tuesday, July 30, 2019 1:36 PM
To:
Cc:
Subject: RE: Wednesday
That is understandable, and thanks for letting us know. Are you referring to meeting at
hotel or at yours? If possible, I
think it would be easier for everyone to meet at
hotel, if you're able to arrange for a conference room there. We are
available to meet at 2 in either case. Thanks.
From:
Sent: Tuesday, July 30, 2019 4:32 PM
To:
Cc:
)
Subject: RE: Wednesday
emailed me that
would feel more comfortable meeting at the hotel. Would you be available to meet at 2 or 3
P.M. instead of at 1P.M. so that there is time for lunch after the court status conference? Also, I have good news. When we
meet tomorrow, I will discuss a third victim whom I represent who would like to meet with you in August in New York.
EFTA00014530

=== Page 2 ===
From:
Sent: Tuesday, July 30, 2019 1:25 PM
To:
Cc:
Subject: RE: Wednesday
Hi
Do you have a sense yet of what time works for you and your client to come to our office tomorrow afternoon?
Thanks,
From:
Sent: Monday, July 29, 2019 6:17 PM
To:
Subject: RE: Wednesday
I understand. I will let you know as soon as I hear from
Also, I am open to having the meeting later than 1P.M.
,because I scheduled that time prior to knowing about the status conference in the morning. Let me see what
wants
to do and then we can discuss the where and when and will work for you.
0
From:
Sent: Monday, July 29, 2019 3:09 PM
To:
Cc:
)
Subject: RE: Wednesday
EFTA00014531

=== Page 3 ===
Hi
Thanks for letting us know about the possible meeting location change- please let us know once you've been able to
confirm with your client, and we can let
know so that she can cancel the car service.
Regarding the court conference, we are unfortunately not able to reserve seats for anyone-the court manages court
security and the crowd, so we don't have control over that. The other victim attorneys have been attending the
conferences on their own, and although I don't know, I would guess that means that they have been arriving early.
Thanks,
From:
Sent: Monday, July 29, 2019 6:00 PM
To:
Subject: RE: Wednesday
Thank you very much for this information. I plan to attend this court this status conference on Wednesday. I am
concerned that the courtroom may be full and no seat will be available for me Would you be kind enough to have
someone on your staff save a seat for me? Also, since the courthouse is very close to your office I have emailed
to
ask if
would be willing to meet at your office instead of at my hotel at 1P.M.Since
hotel is near to your office and
near the courthouse and since I will be in the area now as well, if
feels comfortable meeting at your office instead of
my hotel I am willing to meet at your office to save you and
the time to travel to my hotel. I will let you know when
responds.
erg
1500
From:
Sent: Monday, July 29, 2019 1:50 PM
To:
Subject: RE: Wednesday
Hi
Yes-in this district, criminal defendants are present at all court conferences absent unusual circumstances.
EFTA00014532

=== Page 4 ===
From:
Sent: Monday, July 29, 2019 4:46 PM
To:
Subject: Wednesday
I see that a status conference is scheduled for Mr. Epstein's criminal case in court in New York at 11A.M.on Wednesday
,July 31. Do you know if Mr. Epstein will be present for the status conference in court on Wednesday?
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=== Page 1 ===
Event: Accepted: Epstein Press Meeting
Start Date: 2019-07-01 20:00:00 +0000
End Date: 2019-07-01 21:00:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2019-06-28 16:36:27 +0000
Date Modified: 2019-06-28 16:36:27 +0000
Priority: 5
DTSTAMP: 2019-06-28 14:44:00 +0000
Attendee:
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=== Page 1 ===
From: Nathan NYSD Chambers
To: Jeff Pagliuca
,
Laura Menninger
,
bcsternheim mac.com
,
)"
(USANYS)"
,
)"
=
,
)"
Subject: 20cr330, US V. Maxwell
Date: Sun, 31 Oct 2021 18:06:35 +0000
Attachments: 20cr330_Order_10.31.21.pdf
Counsel:
Attached please find an Order issued by Judge Nathan, which will be docketed tomorrow morning.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Thu, 29 Nov 2018 20:52:27 +0000
Importance: Normal
I'm calling
now
From:
(USANYS)
Sent: Thursday, November 29, 2018 3:27 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: RE: Epstein
I think you should reach out in the first instance and then have the GS call me. We will want to see how quickly they can
gather the FBI investigative file from the old case. We should think about whether there is an immediate subpoena we
should cut to stake claim?
From:
(USANYS)
Sent: Thursday, November 29, 2018 3:14 PM
To:
(USANYS)
>
Cc:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
Subject: Re: Epstein
Agreed.
On Nov 29, 2018, at 2:58 PM,
(USANYS)
wrote:
My view is that we should open on this today, and bring in FBI-NY's sex crimes squad.
please let me know if you
want me to reach out to
or if you prefer to call
(the GS who overseas the squad).
From:
(USANYS)
Sent: Thursday, November 29, 2018 2:53 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Epstein
As discussed: https://www.miamiherald.com/news/local/article220097825.html
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
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=== Page 1 ===
Event: Tentative: 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:
Class: X-PERSONAL
Comment:
Date Created: 2021-06-04 02:12:42 +0000
Date Modified: 2021-06-04 02:12:42 +0000
Priority: 5
DTSTAMP: 2021-06-04 02:10:32 +0000
Attendee:
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=== Page 1 ===
The New York Times
Company
David McCraw
September 10, 2019
Vice President &
Deputy General Counsel
New York, NY 10018
nytimes.com
VIA FAX
The Honorable Kenneth M. Karas
United States District Judge
The Hon. Charles L. Brieant Jr.
Federal Building and United States Courthouse
White Plains, NY 10601
Re:
United States V. Tartaglione, 16-cr-832 - Unsealing of Judicial Records
Dear Judge Karas:
I write on behalf of The New York Times Company and reporter Benjamin
Weiser (jointly, "The Times") regarding the Government's application to seal
two recent filings in this case. The Times agrees with the New York Post and the
Daily News (see Dkt. 155) that the application has no merit: the filings are
judicial documents subject to the common law and First Amendment rights of
access, and the high bar required for overcoming these rights has not been met. 1
The Government has sought to seal records related to Mr. Tartaglione's August
20, 2019 application to "be moved from the [Metropolitan Correctional Center]
and detained at another facility." Dkt. 147 at 1. As the basis for his application,
Mr. Tartaglione's counsel cited the "constant and deplorable" conditions at the
MCC and perceived threats to his client's safety from MCC guards. Id. at 2.
Those threats, he says, arise from his client's speaking up about both the
conditions at MCC and the attempted suicide of his former and now-late cellmate
Jeffrey Epstein. Id. at 1-2. The Government submitted a sealed response to the
application on August 23; Mr. Tartaglione responded in turn, also in a sealed
1 The right of access is an affirmative, enforceable public right, and the
standing of the press to enforce it is well settled. See, e.g., Globe Newspaper Co.
V. Superior Court, 457 U.S. 596, 609 n.25 (1982); Hartford Courant Co. V.
Pellegrino, 380 F.3d 83, 91 (2d Cir. 2004).
EFTA00017095

=== Page 2 ===
filing, on August 28. See Dkt. 152. On August 29, the Government belatedly
filed applications to seal both documents. Dkts. 151, 152. The Government
contends that the documents are not judicial documents subject to the right of
access and that even if they were certain portions of each document should be
redacted. See Dkts. 151, 152.
For reasons stated by the Post and Daily News, the Government is wrong on both
counts. Under the Second Circuit's access jurisprudence, a "judicial document" is
an item "relevant to the performance of the judicial function and useful in the
judicial process." United States V. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995). A
common law presumption of access attaches to any judicial document, and an
additional First Amendment right arises where public access to a document has
been historically available (the "experience" prong) and would be valuable to the
process in question (the "logic" prong). Lugosch V. Pyramid Co. of Onondaga,
435 F.3d 110, 119-20 (2d Cir. 2006). The weight of the common law
presumption turns on "the role of the material at issue in the exercise of Article
III judicial power" and "the resultant value of such information to those
monitoring the federal courts." Bernstein V. Bernstein Litowitz Berger &
Grossmann LLP, 814 F.3d 132, 142 (2d Cir. 2016) (citation and internal marks
omitted). Once the right of access attaches, it is overcome only by
"countervailing factors" (under the common law) or specific, on-the-record
findings that sealing "is essential to preserve higher values and is narrowly
tailored to serve that interest" (under the First Amendment). Id. at 143-45
(citations and internal marks omitted).
The Government contends that the papers filed in connection with Mr.
Tartaglione's transfer application are not judicial documents because they have
"no bearing on the charges contained in the pending indictment" and instead
address a matter "ancillary to his criminal prosecution."2 Dkt. 151 at 1. Not so.
As an initial matter, what makes a record a "judicial document" is not whether it
"directly affect[s]" a criminal prosecution, id. at 2, but what role it plays in the
performance of a judicial function. Applying this standard, the courts have found
the right of access to reach a wide range of records in criminal proceedings. See,
e.g., United States V. Suarez, 880 F.2d 626, 630-31 (2d Cir. 1989) (First
Amendment right of access to forms used for payments to court-appointed
counsel); United States V. Graham, 257 F.3d 143, 151-53 (2d Cir. 2001)
(common law right attaches to audio and video tapes played at pretrial detention
hearing); Applications of National Broadcasting Co., 828 F.2d 340, 344-45 (6th
2 Though the Government articulated this reason only in its application to
seal its own filing, its position on Mr. Tartaglione's filing is presumably based on
the same reasoning.
2
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=== Page 3 ===
Cir. 1987) (First Amendment right of access to records related to motions for
disqualification of judge and for inquiry into attorney conflicts of interest).
The filings sought to be sealed here easily meet the standard for judicial
documents. In seeking a "court order" for his transfer from MCC, Dkt. 147 at 1,
Mr. Tartaglione expressly called upon the Court to exercise its adjudicatory
power over a matter within its purview. Though the Government characterizes its
response to the application as nothing more than a "status report," Dkt. 151 at 2,
its filing and Mr. Tartaglione's response both pertained to the application and
were directed at guiding the Court's resolution of it. 3 That makes them judicial
documents.
What's more, the weight of the common law presumption of access to these
records is undeniably strong. In Graham, the Second Circuit found that the
presumption of access for tapes played at a pretrial detention hearing was, at a
minimum, "substantial": "The detention of criminal defendants pending trial is a
quintessential exercise of a court's Article III judicial power, and the public has a
legitimate interest monitoring a court's use of that power." 257 F.3d at 154. So
too, here. Adjudicating a defendant's grievances about his pretrial confinement,
which has apparently impacted the exercise of his constitutional rights, are
matters at the heart of the judicial function. And the public has a considerable
interest in monitoring how the court discharges that function. Perhaps more than
anything, the public's confidence in the judiciary depends on openness of court
records and proceedings. On this point, Chief Justice Burger's words in
Richmond Newspapers V. Virginia are particularly apt:
People in an open society do not demand infallibility from their
institutions, but it is difficult for them to accept what they are prohibited
from observing. When a criminal trial is conducted in the open, there is
at least an opportunity both for understanding the system in general and
its workings in a particular case.
3 This is true regardless of the merits of Mr. Tartaglione's application.
The Government asserts that "[a] pre-trial detainee does not have the right to be
housed at the facility of his choice." Dkt. 151 at 2 (citation and internal marks
omitted). The Times does not take the Government to be arguing that the
conditions of Mr. Tartaglione's confinement or his personal safety are entirely
outside the Court's purview or that the Court is without any power whatsoever to
address those matters.
3
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448 U.S. 555, 572 (1980) (plurality opinion).4
The seriousness of Mr. Tartaglione's alleged grievances here bear emphasis, too.
As the Post and Daily News point out, the conditions of Mr. Tartaglione's
confinement "relate to his ability to prepare for trial and present an adequate
defense." Dkt. 155 at 1. His attorney claims that his client's opportunities to
review legal documents have been limited, and that members of the legal team
have sometimes waited "hours" to see him. Dkt. 147 at 1. Whether "direct[]" or
not, Dkt. 151 at 2, the impact of a transfer on Mr. Tartaglione's prosecution is
potentially significant.
On the question of whether the access right is overcome, the Government's
arguments again fall short. It says that portions of Mr. Tartaglione's filing
"restate the internal deliberations of the BOP" and that their disclosure would
jeopardize the agency's "law enforcement functions and internal deliberative
processes." Dkt. 152. It elaborates on these points in its application to seal its
own filing. See Dkt. 151 at 3 (disclosing considerations that inform BOP
decisionmaking would hamper candid communications and cause "inmates to
alter their behavior and manipulate their housing assignments").
Though obviously not privy to these portions of the filings, The Times is
skeptical that disclosure would cause the parade of horribles described by BOP.
BOP suggests that the deliberative material in its filing would be exempt from
disclosure under Exemption 5 of the Freedom of Information Act. Id. at 3. To
begin with, FOIA - a right of access created solely by statute - has no bearing on
the common law or constitutional right of access. FOIA, by its terms, does not
apply to the judiciary, and public access to judicial documents is premised on the
4 Both prongs of the First Amendment analysis are met, too: there is a
history of public access to proceedings related to conditions of confinement, and
openness of those proceedings and records would undoubtedly enhance the
functioning of the process. Cf., e.g., Newman V. Graddick, 696 F.2d 796, 801
(11th Cir. 1983) (right of access to civil trials pertaining to confinement
conditions); Graham, 257 F.3d at 154 ("The bail decision is one of major
importance to the administration of justice, and openness will help to assure the
public that the decision is properly reached.") (quoting In re Globe Newspaper
Co., 729 F.2d 47, 52 (1st Cir. 1984) (internal marks omitted)). And even if there
were no history of openness, the mere "logic" of public access is a sufficient
basis for the First Amendment right. See, e.g., Suarez, 880 F.2d at 631; United
States V. Index Newspapers LLC, 766 F.3d 1072, 1094 (9th Cir. 2014) ("logic
alone, even without experience, may be enough to establish the [First
Amendment] right") (citation and internal marks omitted).
4
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=== Page 5 ===
public's historic need to monitor the functioning of the courts. See, e.g., Eil V.
U.S. Drug Enforcement Admin., 878 F.3d 392, 398 (1st Cir. 2017).
Even were that not so, and FOIA were relevant (it is not), there is no reason to
think that the information contained in the BOP filing is genuinely deliberative,
or that the Government could show - as access jurisprudence requires it to - that
disclosure poses some credible risk of harm. See, e.g., Bernstein, 814 F.3d at 143
(finding that disclosure would not "reveal details of an ongoing investigation,
pose a risk to witnesses, endanger national security, or reveal trade secrets"). It
seems unlikely that publicly disclosing the factors that BOP considered in
deciding whether to transfer Mr. Tartaglione - matters that BOP was comfortable
disclosing to Mr. Tartaglione himself and to this Court - would actually have a
chilling effect on agency deliberations.
Nor is there serious reason to think that inmates, armed with this new
information, would succeed in any effort to "manipulate their housing
assignments." Setting aside the question of whether, as a general matter, inmates
should be kept in the dark about the reasons for their assignment to a given
facility, BOP has made clear that Mr. Tartaglione's case is "exceptional." Dkt.
151 at 3. Inmates "seeking to take advantage of similar accommodations," id.,
would be on notice of that fact. And even if some inmates cynically tried to
obtain those accommodations, The Times trusts that BOP, with its substantial
expertise and experience in these matters, would see through those efforts. In
short, BOP's proffered basis for sealing does not meet the high burden imposed
by the common law, particularly in the face of a weighty presumption of access.6
See, e.g., Graham, 257 F.3d at 154-55; Bernstein, 814 F.3d at 143-44.
On a final note, the immense public interest in these proceedings is worth
highlighting. Even before Mr. Tartaglione became Jeffrey Epstein's cellmate,
there was substantial public attention on his case because of the nature of the
5 The deliberative process privilege in Exemption 5 is limited to material
that is both "predecisional," i.e., "prepared in order to assist an agency
decisionmaker in arriving at his decision," and "deliberative," i.e., "actually
related to the process by which policies are formulated." Hopkins V. U.S. Dep 't of
Hous. & Urban Dev., 929 F.2d 81, 84 (2d Cir. 1991) (citations, alteration, and
internal marks omitted).
6 Because the basis for sealing is insufficient to overcome the common
law right of access, it also necessarily cannot defeat the First Amendment right.
See Lugosch, 435 F.3d at 124.
5
EFTA00017099

=== Page 6 ===
charges against him and the prosecutors' decision to seek the death penalty. Mr.
Epstein's attempted suicide, which occurred while Mr. Tartaglione was his
cellmate, roused even greater interest in his case.⁸ Put simply, the public is
watching this case. The public is aware of Mr. Tartaglione's claims that BOP
correctional officers have sought to silence him.⁹ The irony of the Government's
efforts to keep records regarding those claims out of public view is surely not lost
on it.
We thank the Court for its consideration.
Respectfully submitted,
David E. McCraw
cc:
All counsel of record (via e-mail)
7 See, e.g., Andrew Denney, Prosecutors to seek death penalty for ex-cop
in quadruple homicide, New York Post (Mar. 21, 2019), https://bit.ly/2m7DJoL.
8 See, e.g., William K. Rashbaum et al., Jeffrey Epstein Is Found Injured
in Jail Cell, New York Times (July 25, 2019), https://nyti.ms/2kbOXbe.
9 See, e.g., Emily Saul, Jail guards threatening former Epstein cellmate
Nicholas Tartaglione: lawyer, New York Post (Aug. 20, 2019),
https://bit.ly/2m2hjFg.
6
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=== Page 1 ===
From:
To:
Subject: RE: Arrest Today
Date: Thu, 02 Jul 2020 12:53:58 +0000
All good here. Just wanted to let you know before you started worrying about logistics for the day before a holiday
weekend (during a pandemic).
Have a good weekend.
From:
>
Sent: Thursday, July 2, 2020 8:52 AM
To:
Subject: Re: Arrest Today
thank you for the heads up. Hope all is well.
Sent from my BlackBerry - the most secure mobile device
From:
Sent: July 2, 2020 8:50 AM
To:
Subject: Arrest Today
Just a heads up that we are unsealing an indictment this morning against Ghislane Maxwell, an associate of Jeffrey
Epstein, charging her with facilitating his abuse of minors. She was arrested in New Hampshire this morning, so the
presentment will not be in SDNY. She will not appear in SDNY today. Let me know if you have any issues.
Chief, Criminal Division
United States Attorney's Office, SDNY
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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
July 17, 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:
The Government respectfully submits this letter to briefly respond to one aspect of the
defendant's July 16, 2019 letter (ECF No. 24), and to provide the Court with additional information
regarding the defendant's foreign passport. The defendant's July 16, 2019 letter asserts: "[A]s for
the Austrian passport the government trumpets, it expired 32 years ago. And the government offers
nothing to suggest-and certainly no evidence-that Epstein ever used it." (ECF No. 24 at 7). In
fact, the passport contains numerous ingress and egress stamps, including stamps that reflect use
of the passport to enter France, Spain, the United Kingdom, and Saudi Arabia in the 1980s.
The Government further notes that the defendant's submission does not address how the
defendant obtained the foreign passport and, more concerning, the defendant has still not disclosed
to the Court whether he is a citizen or legal permanent resident of a country other than the United
States.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
/s
/
Assistant United States Attorneys
Southern District of New York
Tel:
Cc:
All counsel of record (Via ECF)
EFTA00016172


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 344 Filed 10/14/21 Page 1 of 2
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/14/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Court received a letter via email from a lawyer for an alleged victim regarding victim
attendance at the upcoming trial. The Court will file the letter under seal and forward a copy to
counsel for both sides.
Consistent with the District's COVID-19 protocols, the Court will ensure public access
for pre-trial proceedings and trial, including several overflow rooms at the courthouse with live
feeds of the proceedings. Additional information will be provided as soon as it is available.
Access for alleged victims will be coordinated between the Victim Witness Unit and the
District Executive's Office. The contact information for each office is provided below.
Furthermore, Defense counsel may coordinate access for the Defendant's family members with
the District Executive's Office.
Wendy Olson, Coordinator
Joseph Pecorino
Victim Witness Unit
District Executive's Office
United States Attorney's Office
United States District Court
(212) 637-1028
Southern District of New York
Wendy.Olson@usdoj.gov
(212) 805-0504
Joseph_Pecorino@nysd.uscourts.gov
so ORDERED.
1
EFTA00016513

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 344 Filed 10/14/21 Page 2 of 2
Dated: October 14, 2021
Alim D. N. Notto
New York, New York
ALISON J. NATHAN
United States District Judge
2
EFTA00016514


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From:
To:
Cc:
Subject: Re:
Date: Wed, 22 Jan 2020 13:04:53 +0000
Yes, we will have them reach out and follow up.
Sent from my iPhone
> On Jan 22, 2020, at 7:33 AM,
wrote:
>
> Can someone from the Epstein team contact the Trustees today for the prior trusts.
EFTA00016961


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
Cc:
)"
(USANYS)"
)"
Subject: RE: testifying witness notes
Date: Tue, 17 Aug 2021 12:44:46 +0000
Thank you!
From:
(USANYS) [Contractor]
Sent: Monday, August 16, 2021 9:12 PM
To:
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
i
Subject: RE: testifying witness notes
All set, this has been saved to both folders.
From:
Sent: Monday, August 16, 2021 7:29 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
i
Subject: testifying witness notes
Hi
and
Would you please save the attached pdf in
testifying witness 3500 folder and in his witness folder on the
Epstein share?
Thanks,
EFTA00015874


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Epstein - Scheduling Call
Date: Mon, 29 Jul 2019 23:11:26 +0000
Thank you,
From:
)
Sent: Monday, July 29, 2019 5:41 PM
To:
Cc:
)
Subject: RE: Epstein - Scheduling Call
that works for us, thanks. Also, separately, regarding the return of property, you should feel free to contact Special
Agent
directly, her number is
or alternatively I expect
be in court on Wednesday so you
could speak with
directly then.
thank you,
From:
Sent: Monday, July 29, 2019 16:59
To:
Cc:
Subject: Epstein - Scheduling Call
Dear all -
Can we plan on a call regarding Epstein scheduling issues for Wed morning at 9 am using the following dial in:
EFTA00014542

=== Page 2 ===
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
i
(USANYS)"
Subject: Re: Epstein FOIA Update
Date: Wed, 04 Aug 2021 22:30:51 +0000
Thanks very much! We really appreciated your support and wise insights into how to approach recent issues in
the case.
Thanks,
On Aug 4, 2021, at 4:18 PM,
(USANYS)
wrote:
Thanks
!
From:
(USANYS)
Sent: Wednesday, August 4, 2021 3:58 PM
To:
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: Epstein FOIA Update
and
I understand that Judge Engelmayer has so-ordered the dismissal of the Epstein/BOP FOIA case.
I know that this was a challenging and thankless matter.
Please allow me to thank you on behalf of the Office. The matter required close review of many documents --- with the
judge was closely watching our every step.
You handled the matter with diligence and excellent judgment.
Thank you!!
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=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Date: Thu, 11 Mar 2021 15:50:27 +0000
I am working with EOUSA presently and should have an answer shortly.
FOIA Office
Ph:
Cell
From:
Sent: Wednesday, March 10, 2021 5:44 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Oh, sorry: our FOIA Tracking Database is designed to cover FOIA requests that are directed to our Office; it
does not track FOIA requests to, e.g., the FBI, that end up in litigation in the SDNY and that our Civ Div
defends.
From:
Sent: Wednesday, March 10, 2021 5:40 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Thanks,
could you please check your records and let us know if there are any other cases? From
S list, it
seems like at least one case is missing (there is a civil case involving a FOIA request from Radar Online).
From:
Sent: Wednesday, March 10, 2021 5:23 PM
To:
Cc:
is
(USANYS)
Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
As we just discussed:
Here is what we have in our FOIA tracking database regarding Epstein FOIAs.
And also attached is the letter in PPI about discovery vs FOIA (see p. 8)
From:
Sent: Wednesday, March 10, 2021 5:20 PM
To:
Cc:
is
>;
EFTA00017740

=== Page 2 ===
Subject: Jeffrey Epstein/Ghislaine Maxwell/FOIA
Hi
,
Hope you're doing well. Maurene and Lara and I are trying to assemble a list of every FOIA request our office has ever
received (at any point) relating to Jeffrey Epstein and/or Ghislaine Maxwell.
suggested that you'd be the
best point of contact to help us figure this out. Could you please send us the following information:
A list of all FOIA requests our office has received;
For each case, whether a production was made in response to the request; and
Who the AUSA point of contact for the request is.
That would be a big help. Please let us know if you need any information from us to run the search.
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
(USANYS)"
To: Laura Menninger
>, Jeff
Pagliuca
Cc:
)"
)"
)"
(USANYS) [Contractor]"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 20 Nov 2021 21:52:41 +0000
Attachments: 2021.11.20_Maxwell_Discovery_Letter__Corrected.pdf
Laura,
I'm attaching a corrected cover letter for the discovery production. The letter inadvertently listed SDNY_GM_02774195
instead of SDNY_GM_02774105. We have sent a hard drive to your office in Colorado (the FedEx tracking number is 8166
1429 9380). We have also sent a hard drive to your client at the MDC via FedEx. The tracking number for the drive is
8166 1445 3318, and the tracking number for the password is 8166 1445 3307. We are leaving a hard drive at our office
for pickup under Chris's name.
We have uploaded the production except for SDNY_GM_02774100-SDNY_GM_02774104 to USAfx. We could not upload
SDNY_GM_02774100-SDNY_GM_02774104 due to size limitations. The materials have been added to the same USAfx
production folder
shared with you earlier today.
Thanks,
From: Laura Menninger
Sent: Saturday, November 20, 2021 4:17 PM
To:
(USANYS)
i
; Jeff
Pagliuca
Cc:
in
)
>;
)
is
(USANYS) [Contractor]
Subject: [EXTERNAL] RE: US V. Maxwell, 20 Cr. 330 (AJN)
A second question for you - the discovery letter appears to skip bates numbers 2774105-2774194.
Can you please confirm whether that was intentional or let us know what additional documents are contained in that
range?
Thank you,
Laura
From:
(USANYS)
Sent: Saturday, November 20, 2021 12:53 PM
To:
;
; Laura Menninger
>; Jeff Pagliuca
Cc:
is
)
>;
)
>;
(USANYS) [Contractor]
EFTA00014655

=== Page 2 ===
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter.
That will be produced on a hard drive to you. In addition, a supplemental production of testifying witness and non-
testifying witness material and exhibits are also ready to send to you. Attached please find the accompanying cover letter
and indices. Those materials will be on the hard drive as well. We will also produce the testifying witness and non-
testifying witness material and exhibits via USAfx.
Please let us know if you would like to pick up the drive today or if you would like us to FedEx it (and if so, to where).
Please let us know if you would like us to send today via FedEx a hard drive with these materials to Ms. Maxwell at the
MDC or bring the hard drive to court on Tuesday.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
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=== Page 1 ===
BSF
BOIES
SCHILLER
FLEXNER
December 15, 2020
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
submits the following statement in opposition to the Defendant's renewed
motion for bail.
I appreciate the opportunity to again be heard by the Court in this matter and once more
request that Ghislaine Maxwell not be released prior to her trial. I write this not only on behalf of
myself, but all of the other girls and young women who were victimized by Maxwell. Ghislaine
Maxwell sexually abused me as a child and the government has the responsibility to make sure
that she stands trial for her crimes. I do not believe that will happen or that any of the women she
exploited will see justice if she is released on bail. She has lived a life of privilege, abusing her
position of power to live beyond the rules. Fleeing the country in order to escape once more would
fit with her long history of anti-social behavior.
Drawing on my personal experience with Maxwell and what I have learned of how she has
lived since that time, I believe that she is a psychopath. Her abuse of me and many other children
and young women is evidence of her disregard for and violation of the rights of others. She has
demonstrated a complete failure to accept to responsibility in any way for her actions and
demonstrated a complete lack of remorse for her central role in procuring girls for Epstein to abuse.
She was both charming and manipulative with me during the grooming process, consistent with
what many of the women she abused have described. She has frequently lied to others, including
repeatedly lying about me and my family. Maxwell has for decades lived a parasitic lifestyle
relying on Epstein and others to fund her lavish existence.
Maxwell has repeatedly demonstrated that her primary concern is her own welfare, and
that she is willing to harm others if it benefits her. She is quite capable of doing so once more. She
will not hesitate to leave the country irrespective of whether others will be on the hook financially
for her actions because she lacks empathy, and therefore simply does not care about hurting others.
She would in fact be highly motivated to flee in order to reduce the possibility of continued
imprisonment, the conditions of which she has continuously complained. Her actions over the last
several years and choice to live in isolation for long periods suggest that being comfortable is more
BOIES SCHILLER FLEXNER LLP
401 East Las Olas Boulevard, Suite 1200. Fort Lauderdale, FL 33301 I (t) 954 356 0011 I (f) 954 356 0022 I www.bsfllp.com
EFTA00016024

=== Page 2 ===
important to her than being connected. Even more concerning, is if she is let out she has the ability
to once again abuse children and the painful consequences of that type of trauma can last a lifetime.
I implore the Court to make sure that Ghislaine Maxwell does not escape justice by keeping her
incarcerated until her trial.
***
Respectfully submitted,
EFTA00016025


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Thu, 27 Jun 2019 20:28:51 +0000
Importance: Normal
We obtained the list of victims in the side-letter to the NPA, and confirmed that our principal NY victim is not on it - it
appears that all the victims are Florida.
Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
EFTA00014466


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: Preclude cross
Date: Sat, 27 Nov 2021 02:01:37 +0000
Attachments: 2021-11-26_GM_mot_to_preclude_cross_v2.docx
Hey team,
Letter to preclude cross attached.
per our conversation, I left blanks for the facts of MV-1 and MV-2's drug
use. I think you can just write a couple sentences - it doesn't have to be long.
Otherwise, welcome all comments, and please make sure the section on MV-1's family is accurate!
Thanks
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00016494


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=== Page 1 ===
From:
To:
Subject: RE: Scheduling
Date: Mon, 06 Jan 2020 19:44:44 +0000
That works for us. Thanks
Original Message
From:
Sent: Monday, January 6, 2020 1:14 PM
To:
Cc:
Subject: RE: Scheduling
How's 1130-1230?
Original Message
From:
Sent: Monday, January 6, 2020 1:13 PM
To:
Cc:
Subject: Re: Scheduling
An hour
Sent from my iPhone
> On Jan 6, 2020, at 1:12 PM,
wrote:
>
> Sure we'll be able to make something work how long do you anticipate it to go?
>
>
Original Message
> From:
> Sent: Monday, January 6. 2020 1:11 PM
> To:
> Cc:
> Subject: Scheduling
V
> Hey
V
> Geoff would like us to schedule a meeting on Epstein
/
with all brass. Is there any time before 3 pm on
Thursday?
V
V
> Sent from my iPhone
EFTA00016752


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=== Page 1 ===
J7irepsd
1
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
UNITED STATES OF AMERICA
4
V.
19 CR 490 (RMB)
5
JEFFREY EPSTEIN,
Bail Decision
6
Defendant.
7
X
New York, N.Y.
8
July 18, 2019
11:30 a.m.
9
Before:
10
HON. RICHARD M. BERMAN
11
District Judge
12
13
APPEARANCES
14
15
United States Attorney for the
16
Southern District of New York
17
18
Assistant United States Attorneys
19
MARTIN WEINBERG
20
MARC FERNICH
JOMES BROCHIN
21
MICHAEL MILLER
Attorneys for Defendant
22
23
Also Present:
24
- Special Agent FBI
Detective NYPD
25
- Pretrial Services Officer
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014629

=== Page 2 ===
J7irepsd
2
1
(Case called)
2
THE COURT: I had hoped to have a written decision and
3
order by now, which I don't, one that is regarding the
4
release/remand of Mr. Epstein, which has been the subject of
5
multiple written submissions and, as you all know, an in-court
6
hearing on Monday, July 15, 2019. It is not quite physically
7
produced yet and it needs to be cite checked, but I should have
8
it on the docket in the next hour, two hours at most. What I
9
will do, however, is state the conclusions in the decision and
10
order, which I had said I would do, and summarize very briefly
11
the contents of the ruling for you.
12
Starting with my conclusions, the government's
13
application for continued remand is hereby granted and the
14
defense application for pretrial release is respectfully hereby
15
denied. Written opinion to follow.
16
In that opinion I will deal with all, I'll try to, all
17
the principal issues which have been briefed. Even though it
18
is not entirely necessary or legally required to consider both
19
dangerousness to others and to the community as well as risk of
20
flight, I have done SO. I also deal with the defense's
21
proposed bail package. There is obviously significant public
22
interest in all of these legal issues, so I tried to cover them
23
all as best I could.
24
There are the following headings in the decision and
25
order. First is a background section, followed by counsel's
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014630

=== Page 3 ===
J7irepsd
3
1
submissions. Those are the written submissions: principally
2
the indictment, the legal principles governing release versus
3
remand, the presumption of remand in 18 U.S.C. section 1591
4
cases, danger to others and the community. This topic has
5
seven subsections and fills over ten pages of the decision and
6
order. I think it is fair to say that it is the heart of this
7
decision, that is to say, dealing with danger to others and to
8
the community.
9
Then I deal with risk of flight. That has four
10
subsections or factors, which are substantially the same
11
factors that are used to analyze dangerousness.
12
Then, finally, the bail package proposed by the
13
defense. Specifically, I find in the decision and order that
14
the government has established dangerousness to others and to
15
the community by clear and convincing evidence and also that
16
the government has established risk of flight by a
17
preponderance of the evidence. I also reject the proposed bail
18
package as irretrievably inadequate and go on in some detail
19
concerning what I consider to be its deficiencies.
20
Incidentally, I am not suggesting that a different
21
bail package would be appropriate because I doubt that any bail
22
package can overcome danger to the community.
23
I focus then on dangerousness to others, most
24
certainly including the minor victims in this case and
25
prospective victims as well. I cite and quote, for example,
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014631

=== Page 4 ===
J7irepsd
4
1
the compelling testimony of
, who
2
testified that they fear for their safety and the safety of
3
others if Mr. Epstein were to be released.
4
I also point out that the presumption of remand, as
5
opposed to the presumption of release, is unusual in our
6
jurisprudence and that it attaches only to very serious crimes,
7
such as sex trafficking involving minor victims, as in this
8
case some allegedly as young as age 14.
9
I also discuss evidence of intimidation and threats
10
and compensation paid to potential witnesses and the facts
11
surrounding whether or not Mr. Epstein has been compliant with
12
his legal obligations as a registered sex offender.
13
When discussing risk of flight, which you obviously
14
can tell comes after, in my analysis, dangerousness to the
15
community, when discussing that aspect, risk of flight, the
16
decision speaks to the seriousness of the charged crimes, to
17
Mr. Epstein's great wealth and his vast resources, which
18
include private planes and frequent international travel and
19
also a foreign residence in Paris.
20
I mention the items very recently seized from Mr.
21
Epstein's New York City mansion pursuant to lawful search
22
warrants, which include sexually explicit photos and discs,
23
some $70,000 in cash, diamonds, and an expired Austrian
24
passport with Mr. Epstein's photo but with a name that is
25
different from Jeffrey Epstein, and also contains a reference
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014632

=== Page 5 ===
J7irepsd
5
1
to Saudi Arabia as a residence.
2
I think I have given you a fair account of the
3
decision and order. As I said before, the written version in
4
its complete form, which will be about 30 to 34 pages long I
5
imagine, I hope will be available reasonably soon.
6
One piece of business in light of today's ruling. I
7
thought I would schedule a conference with the parties for
8
Wednesday, July 31, at 11:00 a.m. That is not fixed in stone.
9
If you all want to meet and confer and let me know if that is a
10
convenient date, or I'm happy to accommodate you with another
11
date as well.
12
For the moment, I'll tentatively schedule a conference
13
for July 31st at 11:00 a.m. and ask if there is an application
14
for exclusion of speedy trial.
15
: Yes, your Honor. The government moves to
16
exclude time under the Speedy Trial Act from today's date until
17
July 31st.
18
THE COURT: I am going to find under 18 United States
19
Code section 3161 that adjournment to and including July 31 at
20
11:00 a.m. is appropriate and warrants exclusion of the
21
adjourned time from speedy trial calculations. I further find
22
that the exclusion is designed to prevent any possible
23
miscarriage of justice, to facilitate these proceedings, and to
24
guarantee effective representation of and preparation by all
25
counsel for both parties, both sides. Thus, the need for
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014633

=== Page 6 ===
J7irepsd
6
1
exclusion and the ends of justice outweigh the interests of the
2
public and the defendant in a speedy trial pursuant to 18
3
U.S.C. section 3161 (h) (7) (A) and (B).
4
Finally, a word about the proposed conference. From
5
my point of view, it would be more or less a scheduling/case
6
management type conference, but I'm happy to consider any
7
issues that you might have at that time.
8
I think that's it. Everybody, thank you for being
9
here. We are adjourned.
10
(Adjourned)
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014634


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=== Page 1 ===
From:
)"
To: "Biase, Nicholas (USANYS)"
, "Margolin, James (USANYS)
[Contractor]"
Subject: Fwd: US V. Maxwell, 20 CR. 330 (AJN) - Government Submission
Date: Thu, 17 Dec 2020 02:14:50 +0000
Attachments: 2020-12-16_Government_Cover_Letter_re_GM_Renewed_Bail_Motion.pdf;
ATT00001.htm; 2020-12-
16_Government_Memorandum_in_Opposition_to_GM_Renewed_Bail_Motion.pdf;
ATT00002.htm;, Government_Exhibit_A.pdf;ATT00003.htm; Government_Exhibit_B.pdf;
ATT00004.htm; 2020-12-
16_Government_Memorandum_in_Opposition_to_GM_Renewed_Bail_Motion_[witih_prop
osed_redactions].pdf;ATT00005.htm
Begin forwarded message:
From:
)"
Date: December 16, 2020 at 6:50:00 PM EST
To: Nathan NYSD Chambers
Cc:
)"
(USANYS)"
>, Christian Everdell
N
"Mark S. Cohen"
BOBBI C STERNHEIM
,
>, Laura Menninger
>, , Jeff Pagliuca
Subject: US V. Maxwell, 20 CR. 330 (AJN) - Government Submission
Good evening,
Attached please find the Government's submission in opposition to the defendant's renewed bail application in
the above-referenced case. This submission includes the following documents:
Cover letter
Memorandum of Law
Government Exhibit A
Government Exhibit B
Proposed Redactions to Memorandum of Law
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016023


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=== Page 1 ===
Exhibit A
EFTA00016784

=== Page 2 ===
WILLIAM JULIÉ
AVOCAT À LA COUR
December 18, 2020, Paris.
Response to the government's memorandum in opposition to the defendant's renewed
motion for release.
I was asked to review the United States government's memorandum and notably pages 15 to
17 alongside the French Minister of Justice's letter dated 11 December 2020 produced as
Exhibit B to this memorandum.
1
The French Minister of Justice's letter (Exhibit B)
The letter of the French Minister of Justice, on which the US government relies to argue that
the French government does not extradite its citizens outside the European Union and thus to
the United States, quotes Article 696-2 of the French Code of Criminal Procedure, which
provides that France can extradite "any person not having French nationality".
It remains unclear whether the author of such letter had actually access to my opinion which is
not even quoted, and more generally it seems the letter responds to a question which
unexpectedly was not disclosed.
The letter fails to mention, however, that Article 696 of the same Code provides that provisions
of the French Code of Criminal Procedure on the conditions of extradition apply in the absence
of an international agreement providing otherwise (Article 696 of the French Code of
Criminal Procedure: "In the absence of an international agreement stipulating otherwise, the
conditions, procedure and effects of extradition shall be determined by the provisions of this
chapter¹. These provisions shall also apply to matters which would not have been regulated by
international conventions"). The provisions of Article 696 of the French Code of Criminal
Procedure are a reminder that under Article 55 of the French Constitution, international
agreements prevail over national legislation (Article 55 of the French Constitution: "Treaties
or agreements that have been duly ratified or approved have, upon their publication, an
authority superior to that of laws, subject, for each agreement or treaty, to its application by
the other party"). It follows from these provisions that the key question is whether France may
extradite a French national under the Extradition Treaty between the USA and France and/or
under the Extradition Treaty between the European Union and the USA, not whether France
extradites its citizens under French legislation.
In accordance with this French constitutional rule, the administrative circular of 11 March 2004,
published by the French Ministry of Justice, which aims at specifying how the then recently
amended legal provisions regarding extradition should apply and be understood, states the
following: "Article 696 of the Code of Criminal Procedure reaffirms this principle of
1 The relevant chapter includes Articles 696-1 to Article 696-47-1 of the French Code of Criminal Procedure,
and thus includes Article 696-2.
EFTA00016785

=== Page 3 ===
WILLIAM JULIÉ
AVOCAT À LA COUR
subsidiarity of domestic law in relation to international instruments as stated by the
aforementioned law of 10 March 1927: the legislative provisions on extradition are applicable
only in the silence or in the absence of international conventions."
It follows from the provisions of Article 696 of the French Code of Criminal Procedure that the
key question is whether France may extradite a French national under the Extradition Treaty
between the USA and France and/or under the Extradition Treaty between the European Union
and the USA, not whether France may extradite its citizens under French legislation.
As previously outlined, the Extradition Treaty between the USA and France does not preclude
the French government from extraditing a French national and must therefore be distinguished
from a number of other international agreements signed by France which contain a clear
prohibition to that extent. The Treaty between the USA and France gives the French
government discretion as to whether or not to extradite its own citizens to the USA.
It is noted that the letter of the French Minister does not provide any answer on this issue.
2
The DOJ Memorandum and the Peterson Case
In support of its argument that the French government would not extradite Ms Ghislaine
Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French
American citizen whose extradition to the US was denied by France in 2007.
The Peterson precedent should only be cited with great caution. First, I am not aware that this
case has given rise to a published judicial decision, therefore it should not be interpreted as the
support of any legal rule or principle. In addition, in regards to the documents that the DOJ has
referred to in its memorandum, I doubt that a judicial decision has ever occurred in this case:
as mentioned by the 2007 letter of US Senators Richard J. Durbin and Barack Obama to the
French Minister of Foreign Affairs, the French Minister of Justice communicated its decision
refusing extradition on August 22nd 2007, only a few days after the suspect was arrested (at the
beginning of August 2007). This decision is not a Court decision but a discretionary decision
from the French Ministry of Justice. It actually seems very unlikely that a court decision could
have been rendered in this timeframe. This indicates that the case must not have been handed
on to the court by the Ministry of Justice in the earliest stage of the extradition process.
A refusal to extradite may possibly be challenged by the requesting government before the
French Conseil d'Etat, which is the French Supreme Court for administrative matters, as for
example the United Kingdom and Hong Kong successfully challenged a decision from the
French authorities not to extradite an individual whose extradition they had requested (Conseil
l'Etat, 15 October1993, no. 142578). In the Peterson case, the American government did not
2 Circulaire Mandat d'arrêt européen et Extradition n° CRIM-04-2/CAB-11.03.2004 du 11 mars 2004
-
EFTA00016786

=== Page 4 ===
WILLIAM JULIÉ
AVOCAT À LA COUR
challenge the refusal before French courts, while such challenge could have led to a judicial
review of the request, in accordance with the ordinary extradition procedure.
Secondly, in the absence of a published judicial decision, it is impossible to determine what the
outcome of this case would have been if it had come before the courts.
Third, as was rightly pointed out by US Senators Richard J. Durbin and Barack Obama in their
aforementioned letter to the French Minister of Foreign Affairs, which the government cites in
its memorandum:
"Article 3 of the Extradition Treaty between the United States and France provides in
pertinent part that "There is no obligation upon the Requested State to grant the
extradition of a person who is a national of the Requested State". While this Article
does not require the extradition of a national to a requesting state, it also does not
appear to preclude extradition. To the extent there is discretion available in such
extradition decisions, we urge the French government to exercise that discretion in
favor of extradition".
I am satisfied that this is the right interpretation of Article 3, as this is exactly the conclusion I
came to in my first report. To the extent that there is a discretion, there can be no absolute rule
against the extradition of nationals under French law. A discretionary power is not a legal rule.
Indeed, there is no constitutional principle against the extradition of nationals. For these
reasons, the Peterson case does not alter my view that under the specific and unique facts of
this case, it is highly unlikely that the French government would refuse to issue and execute an
extradition decree against Ms. Maxwell, particularly if Ms. Maxwell has signed an irrevocable
waiver in the USA.
Finally, if an extradition request were to be issued against a French citizen today, the obligations
of the French government under the Extradition Treaty between the USA and France would
also need to be read in light of the Agreement on extradition between the European Union and
the United States of America, which came into force on February 1st, 2010, several years after
the Peterson case. Article 1 of this Agreement, which enhances cooperation between
Contracting Parties, provides that: "The Contracting Parties undertake, in accordance with the
provisions of this Agreement, to provide for enhancements to cooperation in the context of
applicable extradition relations between the Member States and the United States of America
governing extradition of offenders". The existence of this Agreement would need to be taken
into account by the French government in the exercise of its discretion as to whether or not to
grant the extradition of a French national to the USA.
William JULIE
of
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=== Page 1 ===
From:
To: "Strauss, Audrey (USANYS)"
Subject: FW: GM Press Materials
Date: Sun, 28 Jun 2020 00:19:03 +0000
Attachments: Ghislaine_Maxwell_Press_Remarks_v3_(ig_edits).docx
I have some thoughts and edits on the draft remarks for your consideration in the attached version. As you'll see, they're
principally geared toward simplifying some of the language and shortening sentences. Thanks.
From: Strauss, Audrey (USANYS)
Sent: Saturday, June 27, 2020 8:39 AM
To:
Cc:
-
Subject: Re: GM Press Materials
Many thanks.
Sent from my iPhone
On Jun 26, 2020, at 6:45 PM,
wrote:
Audrey - We've put together some draft remarks and a Q&A for a potential press conference next week. The team is
also working with the press office to put together a visual. Happy to discuss further after you've had a chance to review.
Thanks,
<Ghislaine Maxwell Press Remarks v3.docx>
<Maxwell possible QA v2.docx>
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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10982121 approved by
now awaiting further
approval
Date: Tue, 28 Jan 2020 16:12:36 +0000
Importance: Normal
Dear
Travel authorization 10982121 has been approved by
, now awaiting further approval.
Trip ID: 10982121
Traveler name:
Purpose: R20NYS13341 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
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
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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.
EFTA00016830


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Scheduling
Date: Mon, 06 Jan 2020 18:14:29 +0000
That's great, thanks!
Sent from my iPhone
> On Jan 6, 2020, at 1:13 PM,
wrote:
>
> How's 1130-1230?
V
V
Original Message
> From:
V
Sent: Monday, January 6. 2020 1:13 PM
> To:
> Cc:
> Subject: Re: Scheduling
>
> An hour
V
> Sent from my iPhone
>
>>
On Jan 6, 2020, at 1:12 PM,
wrote:
Sure we'll be able to make something work how long do you anticipate it to go?
Original Message
From:
>>
Sent: Monday, January 6, 2020 1:11 PM
To:
Cc:
>>
Subject: Scheduling
Hey
>>
Geoff would like us to schedule a meeting on Epstein /
with all brass. Is there any time before 3 pm on
Thursday?
Sent from my iPhone
EFTA00016755


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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
Subject: Re: Jeffrey Epstein Agreement
Date: Wed, 25 Jun 2008 12:46:27 +0000
Importance: Normal
I have a dr's apptmt @ 10:45 in ftm laud so call me on my cell.
Original Message
From:
(USAFLS)
To:
(USAFLS)
Sent: Wed Jun 25 08:39:31 2008
Subject: RE: Jeffrey Epstein Agreement
Hi
-- I think I have designed a solution to the 2255 issue and I will call you to discuss the plea. I am still finishing up these search
warrants. As soon as they are done, I will give you a call.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
Original Message
From:
(USAFLS)
Sent: Tuesday, June 24, 2008 9:14 PM
To:
(USAFLS)
Subject: Re: Jeffrey Epstein Agreement
Let's talk about going to the COP
Original Message
From:
(USAFLS)
To: Roy BLACK
>; ; Jack Goldberger
Cc:
(USAFLS)
Sent: Tue Jun 24 16:04:55 2008
Subject: Jeffrey Epstein Agreement
Dear Roy and Jack:
I am just writing to re-state that it is the Government's position that we have a signed, binding agreement and that there is no need for
further modification.
Please keep us informed of the date and time of the change of plea and sentencing.
Thank you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014158


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Letter regarding jail conditions and court appearance
Date: Fri, 21 Aug 2020 18:39:31 +0000
Thanks
From:
(USANYS)
Sent: Friday, August 21, 2020 2:39 PM
To:
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
Left a vm
Co-Chief, Narcotics Unit
On Aug 21, 2020, at 14:36,
(USANYS)
wrote:
Have you tried calling her? I'm in victim interviews, but can try calling her when I free up. If you don't hear back by
3pm, I think we should email again and add
From:
(USANYS)
Sent: Friday, August 21, 2020 2:36 PM
To:
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
Not holding my breath on a response
Co-Chief, Narcotics Unit
On Aug 21, 2020, at 14:23,
(USANYS)
wrote:
Thanks for getting this going.
From:
(USANYS)
Sent: Friday, August 21, 2020 1:25 PM
To:
Cc:
(USANYS)
Subject: FW: Letter regarding jail conditions and court appearance
EFTA00016968

=== Page 2 ===
- Can we please jump on a call this afternoon to discuss? As you can see, we have only until Monday to
respond.
Co-Chief, Narcotics Unit
From: Karas NYSD Chambers
Sent: Friday, August 21, 2020 1:22 PM
To: Bruce Barket
Cc: Aida Leisenring
is
i
>; Michael Bachrach
i
>; John Diaz
is
is
is
(USANYS)
is
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: Re: Letter regarding jail conditions and court appearance
All,
Attached please find a memo endorsement from Judge Karas.
-Chambers of Judge Karas
From: Bruce Barket
Sent: Thursday, August 20, 2020 6:24 PM
To: Karas NYSD Chambers
Subject: FW: Letter regarding jail conditions and court appearance
Good afternoon,
I sent this to
but wanted to forward here as well. Can you confirm that the judge will see it?
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not
clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From: Bruce Barket
Sent: Thursday, August 20, 2020 12:50 PM
To:
Cc: Aida Leisenring
>; tonyricco
is
>; Michael Bachrach
>; ; Kenneth J. Montgomery Esq
EFTA00016969

=== Page 3 ===
>; 'john diaz
(
)'
>;
>;
is
is
(USANYS)
is
(USANYS)
is
(USANYS)
(
)'
Subject: Letter regarding jail conditions and court appearance
I hope all is well. Can you please bring this letter to the attention of the judge? Note that I copied the lawyer for the
MCC and the prosecution team as well as firewall counsel. Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not
clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00016970


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Follow Up Call
Date: Thu, 05 Sep 2019 19:11:16 +0000
Importance: Normal
That works for me, thanks.
From:
)
Sent: Thursday, September 05, 2019 15:06
To:
is
Subject: RE: Follow Up Call
I can respond. Does 3:30 ET work for you guys on 9/12?
From:
Sent: Thursday, September 5, 2019 2:40 PM
To:
is
Subject: FW: Follow Up Call
I'm not going to respond to this one since
S sorting this out, but let me know if I have that wrong. Thanks guys.
From:
Sent: Wednesday, September 4, 2019 6:12 PM
To:
Cc:
>; Gerson, Jonathon (USANM) <JGerson@usa.doj.gov>;
Subject: RE: Follow Up Call
Thank you for the speedy response. Next week works for us. Can you all do the call next Thursday, September 12th at
1:30 MT / 3:30 ET?
From:
Sent: Wednesday, September 04, 2019 3:41 PM
To
Cc.
Subject: RE: Follow Up Call
Hope you're doing well. This week is a bit tough for us. Are there dates next week that would work for you? We are
traveling Monday through Wednesday, but could talk Thursday or Friday.
EFTA00016399

=== Page 2 ===
Thanks,
From:
Sent: Wednesday, September 4, 2019 4:28 PM
To:
Cc:
is
Subject: RE: Follow Up Call
and I were hoping to schedule a follow up call with you concerning Epstein's New Mexico conduct and property
sometime this week. We are both available tomorrow morning (9-12 MT / 11-2 ET) or Friday any time after 12pm MT /
2pm ET. Do you all have availability for a follow up call on either of these days?
Thanks,
From:
Sent: Saturday, August 17, 2019 12:46 PM
To:
Cc:
is
Subject: RE: Follow Up Call
We certainly can be in touch. I'm copying my colleagues on the case
because I have a trial starting
August 26 so l'll be mostly unavailable next week, but it should be possible to find a time for one or both of them to chat.
If you send a couple possible times for next week we can figure it out.
thanks,
From:
Sent: Friday, August 16, 2019 14:01
To:
Subject: Follow Up Call
Would you have a couple of minutes to chat with me and one of my colleagues about some NM-related Epstein matters
this afternoon or early next week? If today works for you, I am available any time after 1:30 MT/ 3:30 ET today. It is
nothing urgent.
Thanks
EFTA00016400


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=== Page 1 ===
From:
)"
To: Parker NYSD Chambers
Cc:
)"
)"
Subject: Application for Warrant for Cellphone Location Information
Date: Mon, 29 Jun 2020 00:46:29 +0000
Attachments: Application_for_Maxwell_GPS_Combo.pdf,Exhibit A -
Maxwell_Indictment_(unsigned).pdf;,1 Exhibit B -
_Maxwell_Arrest_Warrant_(unsigned).pdf
Good evening,
Attached for Judge Parker's review please find an application for two warrants for cellphone location information. The
application incorporates by reference an indictment that the Government intends to present to a grand jury in White
Plains tomorrow and a corresponding arrest warrant. I have attached unsigned drafts of the indictment and arrest
warrant for the Judge's review, and will send signed copies upon completion of the presentation tomorrow morning.
The agent will be available to swear out the warrant as soon as the indictment is returned, which we anticipate will take
place at or around 11:30am tomorrow. I can be reached on my cellphone at
should any questions or
concerns arise.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016348


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell - Letter Due Today at 5 PM
Date: Fri, 15 Oct 2021 18:11:27 +0000
Attachments: 2021-10-15_GM_letter_re_MDC_legal_mail_v3.docx
Hi
Thanks very much for speaking today. We have incorporated our discussion into the attached letter to Judge Nathan.
Would you please review the draft and let us know if there are any inaccuracies in it? I highlighted one sentence in
particular for your attention, but please review the entire letter closely. As we mentioned earlier, our letter is due today
as soon as possible, no later than 5 pm.
Thanks,
From:
Sent: Friday, October 15, 2021 10:28 AM
To:
Cc:
Subject: Maxwell - inmate mail
Hi
and
Maxwell's counsel filed the attached letter last night, and we've been ordered to respond as soon as possible, and by no
later than 5 pm. Is one of you free soon for a call about this?
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00016729


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=== Page 1 ===
From:
To:
Subject: U.S. V EPSTEIN, JEFFREY
Date: Thu, 01 Aug 2019 11:40:59 +0000
Attachments: j7v2epsC.pdf
EFTA00014545


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=== Page 1 ===
From: Christian Everdell
To:
Cc:
Bobbi C. Sternheim, Esq."
Laura Menninger
, Jeff Pagliuca
Subject: [EXTERNAL] RE: Stip
Date: Sun, 21 Nov 2021 04:20:07 +0000
Attachments: Stipulation
Trial_Testimony.PDF
Attached is a clean version of the stip. The only thing I changed from the version you last saw is that we now label the stip
Defendant's Trial Exhibit A.
You can email me the signed version and hand deliver it to me at the conference on Tuesday, whichever works best for
you.
Thanks,
Chris
From:
Sent: Saturday, November 20, 2021 2:37 PM
To: Christian Everdell
Cc:
; Bobbi C. Sternheim, Esq.
>; Laura Menninger
>; ; Jeff Pagliuca
Subject: RE: Stip
Hey Chris,
This works for us. If you send me a clean version, I'll sign and return it to you, or I can just sign it at the conference
Tuesday.
Thanks,
From: Christian Everdell
Sent: Friday, November 19, 2021 9:04 PM
To:
)
Cc:
Bobbi C. Sternheim, Esq.
>; Laura Menninger
>; ; Jeff Pagliuca
Subject: [EXTERNAL] RE: Stip
Following-up on our conversation today, is the revised stipulation acceptable to the government?
EFTA00014683

=== Page 2 ===
From:
Sent: Tuesday, November 16, 2021 7:03 PM
To: Christian Everdell
Cc:
; Bobbi C. Sternheim, Esq.
>; Laura Menninger
>; ; Jeff Pagliuca
Subject: Stip
Hey Chris,
Following up on our conversation today regarding the stip, would you agree to have the sentence say that the document is
a "true and accurate copy of the transcript of one witness's trial testimony, but not the full trial transcript, given on
February 26 If so, we are fine with the stip - and, of course, happy to consider other language that makes the same
point.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00014684


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=== Page 1 ===
From: Brad Edwards
To:
"
"
(USANYS)"
"
)"
Cc: Brittany Henderson
Subject: [EXTERNAL] Trial
Date: Sat, 20 Nov 2021 17:35:41 +0000
We saw the Order. Let us know if or when you want to discuss next steps - if or when you may need her to travel over and the
parameters or scope of her testimony.
Sent from my iPhone
EFTA00014652


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=== Page 1 ===
From:
To:
Bcc:
Subject: 20-3061 United States of America V. Maxwell "Motion FILED to seal document"
Date: Thu, 08 Oct 2020 20:55:27 +0000
Embedded: 20-3061_United_States_of_America_v_Maxwell_"Motion_FILED_to_seal_document".nsg
Sender:
Subject: 20-3061 United States of America V. Maxwell "Motion FILED to seal document"
Message-Id: <1807054018.2244.1602190523721.JavaMail.ecf_web@ca2db.ca2.gtwy.dcn>
Recipient:
EFTA00014594


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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
BANK OF AMERICA
Date: Mon, 29 Jul 2019 13:03:11 +0000
Attachments:
wav
Time: Jul 29, 2019 9:03:11 AM
Click attachment to listen to Voice Message
EFTA00015709


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
)"
(USANYS)"
)"
Subject: RE: Time sensitive review of pending productions
Date: Wed, 24 Nov 2021 20:59:27 +0000
Attachments: 2021.11.24 MDC - Maxwell_PASSWORD.pdf
Additionally, attached is the letter with the password if it's helpful to include it in the email to
and
From:
Sent: Wednesday, November 24, 2021 3:18 PM
To:
(USANYS) [Contractor]
>;
is
(USANYS)
is
Subject: RE: Time sensitive review of pending productions
and I sorted out out. All set.
From:
Sent: Wednesday, November 24, 2021 3:10 PM
To:
(USANYS) [Contractor]
is
is
(USANYS)
is
Subject: RE: Time sensitive review of pending productions
Hi all,
I've reviewed all of the productions and the two cover letters. So everything is reviewed and ready to go except the index
- I just got a time sensitive call. Can someone else look at that?
From:
(USANYS) [Contractor]
Sent: Wednesday, November 24, 2021 2:59 PM
To:
is
is
(USANYS)
is
)
Subject: Time sensitive review of pending productions
Hi all,
If you want to get a production out today (sent on a drive via FedEx to GM), we will need to have it reviewed and ready for
me to load by 3:20pm latest (FedEx last pick up is 4pm today).
The TW 3500 production is here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\3500\1.
Testifying\Production 11
NTW 3500 production is here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\3500\2.Non-
Testifying\Production 11
Rule 16 production is here: \Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\41
Thirty-Second Production (2021-11-xx)
EFTA00016482

=== Page 2 ===
Cover letters for both and 3500 indices (excel version) are attached. Please let me know as soon as you can if there are
any changes you want to make.
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 Saint Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00016483


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Jeffrey Epstein
Date: Sun, 07 Jul 2019 20:44:29 +0000
Importance: Normal
Thanks man - I appreciate it
From:
(USANYS)
Sent: Sunday, July 07, 2019 16:44
To:
Subject: Fwd: Jeffrey Epstein
Congratulations.
Begin forwarded message:
From:
(USANYS)"
Date: July 7, 2019 at 1:08:19 PM EDT
To:
)"
(USANYS)"
Subject: Jeffrey Epstein
Hey PCU - As you likely may have seen/heard at this point, last evening, we arrested Jeffrey Epstein on sex trafficking
charges. Epstein is in custody and will be presented and arraigned on an Indictment that will be unsealed tomorrow
morning.
The case is an incredibly important one - not only is the conduct extremely serious and deeply disturbing - but our
charges ensure that dozens if not more of Epstein's victims, girls who were as young as 14 at the time they were abused,
will finally have their day in court. It is an extraordinarily worthy prosecution and just the latest example of how this
unit will never shy away from bringing tough cases against powerful people who have committed grievous crimes.
Please join me and
in extending a very well-deserved congratulations to the team,
who have worked tirelessly to make this case happen (and happen so quickly). They have done us all proud, and if you
are free, we hope you join us for the press conference formally announcing the charges, which should happen Monday
morning at 11.
&
EFTA00015597


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=== Page 1 ===
From:
"
To:
Subject: Re:
Date: Tue, 16 Jul 2019 18:19:11 +0000
Importance: Normal
Yes I'll come by
Associate U.S. Attorney, SDNY
On Jul 16, 2019, at 1:52 PM,
wrote:
Wanted to touch base on Epstein. Let me know if you have a few minutes.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00014470


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=== Page 1 ===
OF JUSTICE
/
Click here for updates on
United States V. Jeffrey Epstein,
19 Cr. 490 (RMB)
If you believe you were a victim
of Jeffrey Epstein or have
information about the
allegations in the Indictment,
please call 1-800-Call-FBI.


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=== Page 1 ===
10/6/21, 12:18 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a search of the III based on:
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/1
EFTA00015127


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=== Page 1 ===
ACCOUNT NAME
ACCOUNT NUMBER
BILL DATE PAGE 1.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
Wireless Number Multi-Line Account
Previous
Payments
Late Payment
Adjustments
Balance
Current
Balance
Received
Charge
Forward
Charges
1,526.46
1,526.46CR
.00
.00
.00
1,163.10
Your billing cycle began on 09/13 and ended on 10/12.
Total Amt Due
1,163.10
Current Monthly Charges
of Individual Number Charges
CURST CUEST
121.79
52.32
G. MAXWELL
478.74
56.54
453.71
Total Current Monthly Charges
DUE UPON RECEIPT
1,163.10
TOTAL AMOUNT DUE
1,163.10
PAYMENT DUE UPON RECEIPT
AMOUNT DUE:
1,163.10
AT&T WIRELESS
Acct Name: JEFFREY R ERSTEIN & CO
P.O. BOX 8220
Account:
025
AURORA IL 60572-8220
Wireless:
JEFFREY E EPSTEIN & CO
457 MADISON AVE
NEW YORK NY 10022-6843
000000030002500000005592276997140001163106
EFTA00014767

=== Page 2 ===
ACCOUNT NAME
ACCOUNT NUMBER
BILL DATE PAGE 3.0
JEFFREY E EPSTEIN &
OCT 14, 2003
You can now call Canada, Puerto Rico and the U.S. Virgin Islands!
Take your phone with you when you travel to Canada, Puerto Rico or the U.S. Vir
gin Islands.
AT&T Wireless gives customers the capability to dial to and roam in these 3 are
as. You'll use
airtime just like a regular call, and pay for any additional airtime and roamin
g charges based
on your current rate plan. Additional international long distance charges will
apply to all
calling to or from these areas. Other restrictions apply.
Visit attwireless.com/international for details.
PAYMENTS AND ADJUSTMENTS
DETAIL OF PAYMENTS
9/29/03 PAYMENT RECEIVED - THANK YOU!
1,526.46CR
TOTAL OF PAYMENTS RECEIVED THROUGH 10/14/03
1,526.46CR
EFTA00014768

=== Page 3 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE
5.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
9/13/03 Through 10/12/03
MONTHLY SE - AT&T DIGITAL ONE RATE $99
99.99
CALL WAITING
.00
INTL DIALING
.00
PCS VOICEMAIL
.00
CALLER ID
.00
DETAIL BILLING
.00
TOTAL MONTHLY SERVICE CHARGES
99.99
HOME AIRTIME CHARGES
9/13/03 Through 10/12/03 - AT&T DIGITAL ONE RATE $99.99
Category
Minutes
Rate
Charge
AIRTIME
0
.00
TOTAL HOME AIRTIME CHARGES
.00
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
3.27
STATE TAX
4.58
LOCAL TAX
4.71
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
2.04
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
2.18
GROSS RECEIPTS SURCHARGE
3.52
TOTAL TAXES, SURCHARGES & REGULATORY FEES
21.80
TOTAL CURRENT MONTHLY CHARGES
121.79
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014769

=== Page 4 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE
7.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
9/13/03 Through 10/12/03
MONTHLY SE - LOCAL PLAN $39.99
39.99
CALL WAITING
.00
INTL DIALING
.00
CALLER ID
.00
PCS VOICEMAIL W/NUMERIC
.00
DETAIL BILLING
.00
AT&T 2 WAY TEXT MSG $0.00
.00
AT&T TOLL FREE NATIONWIDE
4.99
AT&T TOLL FREE CREDIT
4.99CR
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
41.74
HOME AIRTIME CHARGES
9/13/03 Through 10/12/03
- LOCAL PLAN $39.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
138
.000
.00
300 ADDITIONAL MINUTES
300
.000
.00
INCLUDED IN PLAN
67
.000
.00
505
.00
TOTAL HOME AIRTIME CHARGES
.00
MESSAGING, CONTENT & APPLICATION CHARGES
9/13/03 Through 10/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
5
.10
.50
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.50
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
1.39
STATE TAX
1.93
LOCAL TAX
1.99
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
.86
EFTA00014770

=== Page 5 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER
BILL DATE
PAGE
8.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES (CONTINUED)
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
.92
GROSS RECEIPTS SURCHARGE
1.49
TOTAL TAXES, SURCHARGES & REGULATORY FEES
10.08
TOTAL CURRENT MONTHLY CHARGES
52.32
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001
9/13
8:48A
WASHINGTON MD
4
0002
9/13
8:58A
WASHINGTON MD
4
0003
9/13 11:19A
NEW YORK
NY
1
0004
9/13
5:16P
WASHINGTON MD
2
0005
9/13
6:17P
INCOMING
1
0006
9/13
6:18P
NEW YORK
NY
1
0007
9/14
10:27A
WASHINGTON MD
3
0008
9/14
10:46A
MCLEAN
VA
2
0009
9/15
3:01P
NEW YORK
NY
1
0010 9/15 4:41P
NEW YORK
NY
0011 9/15 7:31P
NEW YORK
NY
1
0012
9/15
7:36P
NEW YORK
NY
1
0013
9/15
7:38P
INCOMING
1
0014
9/15
7:47P
NEW YORK
NY
1
0015
9/15
8:16P
INCOMING
1
0016
9/15
8:37P
NEW YORK
NY
1
0017
9/16
9:08A
NEW YORK
NY
1
0018
9/16
1:12P
NEW YORK
NY
1
0019
9/16
7:59P
NEW YORK
NY
2
0020
9/16
8:12P
INCOMING
1
0021
9/16
8:16P
INCOMING
1
0022
9/17
8:02A
NEW YORK
NY
1
0023
9/17
8:03A
BROOKLYN
NY
1
0024
9/17
8:34A
INCOMING
3
0025
9/17
9:18A
INCOMING
4
0026
9/17
9:31A
NEW YORK
NY
1
0027
9/17
9:44A
NEW YORK
NY
1
0028
9/17
9:46A
WASHINGTON
MD
8
0029
9/17
10:44A
NEW YORK
NY
2
0030
9/17
10:53A
NEW YORK
NY
1
0031
9/17
10:58A
NEW YORK
NY
1
0032
9/17
11:14A
WASHINGTON MD
4
0033
9/17
6:45P
NEW YORK
NY
1
0034
9/18
9:19A
CROFTON
MD
6
0035
9/18
9:26A
A
CROFTON
MD
3
0036
9/18
9:56A
WASHINGTON MD
11
0037
9/18
10:16A
WASHINGTON MD
11
0038
9/18
10:59A
INCOMING
2
0039
9/18
11:39A
WASHINGTON
MD
6
0040
9/18
11:52A
MCLEAN
VA
28
0041
9/18
1:13P
INCOMING
1
0042
9/18
1:35P
NEW YORK
NY
1
0043
9/18
7:56P
WASHINGTON MD
4
0044
9/18
8:07P
INCOMING
1
0045
9/18
8:08P
INCOMING
1
0046 9/19 11:16A S
MCLEAN
VA
1
0047
9/19
6:40P
NEW YORK
NY
I
1
EFTA00014771

=== Page 6 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE
9.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0048 9/20 10:08A
MCLEAN
VA
2
0049
9/20
10:11A
S
WASHINGTON
MD
1
0050
9/20
10:12A
CROFTON
MD
1
0051
9/20
10P
NEW YORK
NY
1
0052
9/20
7:31P
MCLEAN
VA
1
0053
9/20
7:32P
CROFTON
MD
1
0054
9/20
7:32P
S
WASHINGTON MD
1
0055
9/20
7:55P
INCOMING
7
0056
9/20
8:41P
INCOMING
1
0057
9/21
2:00P
WASHINGTON MD
2
0058
9/21
2:02P
FAIRFAX
VA
1
0059
9/21
2:02P
CROFTON
MD
7
0060
9/22
1:14P
INCOMING
1
0061
9/22
1:44P
NEW YORK
NY
1
0062
9/22
1:51P
INCOMING
2
0063
9/22
1:52P
INCOMING
1
0064
9/22
1:53P
NEW YORK
NY
1
0065
9/22
2:42P
LOCAL
1
0066
9/22
2:42P
NEW YORK
NY
2
0067
9/22
3:04P
INCOMING
1
0068
9/23
3:47P
NEW YORK
NY
0069
9/23
3:47P
NEW YORK
NY
1
0070
9/23
3:52P
NEW YORK
NY
3
0071
9/24
10:09A
WASHINGTON
MD
10
0072
9/24
10:50A
INCOMING
1
0073
9/25
9:27A
CROFTON
MD
8
0074
9/25
9:35A
MCLEAN
VA
1
0075
9/25
1:25P
MCLEAN
VA
3
0076
9/26
3:50P
INCOMING
1
0077
9/26
4:00P
NEW YORK
NY
0078
9/26
4:07P
NEW YORK
NY
1
0079
9/26
4:07P
NEW YORK
NY
1
0080
9/26
4:09P
NEW YORK
NY
1
0081
9/26
4:23P
NEW YORK
NY
1
0082
9/26
5:08P
NEW YORK
NY
1
0083
9/26
5:10P
LOCAL
3
0084
9/26
:12P
NEW YORK
NY
1
0085
9/27
2:36P
NEW YORK
NY
4
0086
9/27
3:12P
WESTBURY
NY
3
0087
9/27
4:11P
NEW YORK
NY
1
0088
9/27
4:19P
INCOMING
1
0089
9/27
4:24P
MCLEAN
VA
7
0090
9/27
4:31P
WASHINGTON
MD
9
0091
9/27
4:40P
INCOMING
2
0092
9/27
4:41P
LEVITTOWN
NY
1
0093
9/27
4:42P
NWYRCYZN06
NY
4
0094
9/27
4:51P
NEW YORK
NY
3
0095
9/27
5:22P
NEW YORK
NY
2
0096
9/27
5:25P
WASHINGTON MD
5
0097
9/27
5:29P
FAIRFAX
VA
1
0098
9/27
5:31P
NWYRCYZN06
NY
4
0099
9/27
5:34P
FAIRFAX
VA
2
0100
9/27
6:40P
INCOMING
1
0101
9/28
2:27P
INCOMING
1
0102
9/28
4:22P
FAIRFAX
VA
1
0103
9/28
4:23P
MCLEAN
VA
1
0104
9/28
4:24P
WASHINGTON
MD
0105
9/28
4:24P
CROFTON
MD
2
0106
9/29
1:49P
INCOMING
0107
9/29
1:50P
INCOMING
1
EFTA00014772

=== Page 7 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 10.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0108 9/30 6:01A
LOCAL
1
0109 10/01 9:58A
NEW YORK
NY
3
0110 10/01 11:05A
WASHINGTON
MD
1
0111 10/01 11:06A
NWYRCYZN06
NY
7
0112 10/01 11:14A
LEVITTOWN
NY
51
0113 10/01 12:04P
INCOMING
2
0114
10/01
1:20P
INCOMING
1
0115
10/01
1:41P
NEW YORK
NY
1
0116
10/01
6:30P
WASHINGTON MD
29
0117 10/02 12:19P
NEW YORK
NY
1
0118
10/02
1:19P
INCOMING
1
0119 10/03 8:38P
WASHINGTON MD
7
0120 10/03 10:55P
NEW YORK
NY
1
0121 10/03 11:15P
INCOMING
1
0122 10/03 11:34P
INCOMING
1
0123
10/04
2:06A
S
NEW YORK
NY
2
0124 10/04 4:15A
HYATTVILLE MD
1
0125
10/04
8:37A
800 SERV.
2
0126 10/04 10:41A
800 SERV.
14
0127 10/04 11:23A
LDALEXANDRIA DC NY
0128 10/04 11:24A
INCOMING
2
0129 10/04 12:58P
LDALEXANDRIA DC NY
0130 10/04 12:59P
INCOMING
1
0131 10/04 4:07P
800 SERV.
5
0132 10/04 4:43P
HYATTVILLE MD
2
0133
10/04
6:59P
NEW YORK
NY
1
0134 10/04 10:41P
NEW YORK
NY
1
0135
10/07
1:07P
NEW YORK
NY
1
0136 10/08 11:22A
WASHINGTON MD
39
0137 10/08 12:11P
MCLEAN
VA
1
0138 10/08 12:12P
WASHINGTON MD
6
0139 10/08 3:41P
NEW YORK
NY
1
0140 10/08 3:42P A
NEW YORK
NY
1
0141 10/08 3:43P
NEW YORK
NY
1
0142 10/08 4:41P
INCOMING
2
0143 10/08 4:45P
MCLEAN
VA
21
0144 10/08 5:27P
MCLEAN
VA
1
0145
10/08
5:28P
CROFTON
MD
3
0146 10/09 10:12A
LOCAL
2
0147 10/09 10:52A
INCOMING
2
0148 10/09 11:22A
NEW YORK
NY
2
0149
10/09
1:06P
INCOMING
1
0150 10/09 1:07P
NEW YORK
NY
1
0151 10/09 1:08P
NEW YORK
NY
1
0152 10/09 1:22P
WASHINGTON
MD
1
0153 10/09 1:45P
INCOMING
1
0154 10/09 1:46P
NEW YORK
NY
1
0155
10/09
1:50P
INCOMING
1
0156
10/09
5:30P
NEW YORK
NY
1
0157
10/10
5:03P
INCOMING
1
0158 10/10 10:15P
INCOMING
1
0159 10/11 8:48A
NEW YORK
NY
1
0160 10/11 12:16P
NEW YORK
NY
1
EFTA00014773

=== Page 8 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER
BILL DATE PAGE 11.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0161 10/11 12:25P
INCOMING
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
505
.00
.00
CALL CHARACTERISTICS:
A = Automatic Dropped Call Credit
S = Long Distance Service Billed Separately
"CALLS FROM" KEY:
NY = NEW YORK
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001 9/20 7:51P
.10 0002 9/23 9:10P
0003 10/09 10:19A
.10 0004 10/10 9:47A
S
.10
.10
0005 10/10 9:48A
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.50
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014774

=== Page 9 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE 13.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
9/13/03 Through 10/12/03
MONTHLY SE - AT&T DIGITAL ONE RATE $14
149.99
CALL FORWARDING
.00
THREE WAY CALLING
.00
CALL WAITING
.00
CALLER ID
.00
LINE NUMBER BLOCKING
.00
WORLDCONNECT
7.99
PCS VOICEMAIL W/NUMERIC
.00
DETAIL BILLING
.00
TEXT MESSAGING $9.99
9.99
TOTAL MONTHLY SERVICE CHARGES
167.97
HOME AIRTIME CHARGES
9/13/03 Through 10/12/03 - AT&T DIGITAL ONE RATE $149.99
Category
Minutes
Rate
Charge
INCLUDED IN PLAN
1278
.000
.00
CALL FORWARDING MINS
362
.250
90.50
1640
90.50
TOTAL HOME AIRTIME CHARGES
90.50
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
91.00
TOTAL HOME LONG DISTANCE CHARGES
91.00
MESSAGING, CONTENT & APPLICATION CHARGES
9/13/03 Through 10/12/03
Category
Messages
Rate
Charge
INTERNATIONAL MESSAGES
2
.25
.50
INCLUDED IN PLAN
20
.00
.00
22
.50
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.50
EFTA00014775

=== Page 10 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 14.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES (CONTINUED)
ROAMING CHARGES
ROAMING AIR
47.52
ROAMING LONG DISTANCE CHARGES
15.40
TOTAL ROAMING CHARGES
62.92
OTHER CHARGES AND CREDITS
AT&T CONNECT CALLS
1 CALL
1.25
TOTAL OTHER CHARGES AND CREDITS
1.25
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
11.37
STATE TAX
12.08
LOCAL TAX
12.44
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
7.18
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
7.67
GROSS RECEIPTS SURCHARGE
12.36
TOTAL TAXES, SURCHARGES & REGULATORY FEES
64.60
TOTAL CURRENT MONTHLY CHARGES
478.74
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0001
9/13
1:37A
F
NEW YORK
NY NY
1
.25
0002
9/13
8:57A F
NEW YORK
NY NY
12
3.00
0003
9/13
11:14A
F
NEW YORK
NY NY
1
.25
0004
9/13
11:31A
F
NEW YORK
NY NY
8
2.00
0005
9/13
12:19P
F
NEW YORK
NY NY
3
.75
0006
9/13
12:45P
F
NEW YORK
NY NY
2
.50
0007
9/13
1:03P
F
NEW YORK
NY NY
5
1.25
0008 9/13 1:49P
INCOMING
1
0009
9/13
1:56P
SAN MONICA
CA
1
0010
9/13
3:10P
NEW YORK
NY
1
0011
9/13
3:13P
LOCAL
3
0012
9/13
4:14P
INCOMING
1
0013
9/13
4:49P
NEW YORK
NY
2
0014
9/13
5:06P
NEW YORK
NY
1
0015
9/13
5:12P
INCOMING
1
0016
9/13
5:13P
NEW YORK
NY
1
0017
9/13
5:15P
MIAMI
FL
1
0018
9/13
6:17P
INCOMING
2
0019
9/13
7:28P F
NEW YORK
NY NY
4
1.00
EFTA00014776

=== Page 11 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 15.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0020
9/13 10:10P
INCOMING
1
0021
9/13
10:33P
INCOMING
1
0022
9/13
10:40P
NEW YORK
NY
2
0023 9/13 10:44P
NEW YORK
NY
1
0024
9/13
10:47P
MOBILE
NY
2
0025
9/13
10:48P
MOBILE
NY
1
0026
9/13
10:49P
MOBILE
NY
1
0027
9/13
11:12P
NEW YORK
NY
1
0028
9/13
11:34P
NEW YORK
NY
1
0029
9/14
12:08A
BROOKLYN
NY
1
0030
9/14
12:08A
BROOKLYN
NY
1
0031
9/14
12:10A
MOBILE
NY
1
0032
9/14
11:39A
***
NEW YORK
NY NY
1
.25
0033
9/14
11:54A
NEW YORK
NY NY
2
.50
0034
9/14
12:03P
NEW YORK
NY NY
1
.25
0035
9/14
12:30P
INCOMING
1
0036
9/14
1:15P
INCOMING
9
0037
9/14
2:48P
LOCAL
2
0038
9/14
3:32P
INCOMING
1
0039
9/14
3:35P
NEW YORK
NY
1
0040
9/14
3:58P
NEW YORK
NY
1
0041
9/14
3:59P
NEW YORK
NY
1
0042
9/14
4:18P
UN. KINGDO
1
.350
0043
9/14
4:18P
UN. KINGDO
1
.350
0044
9/14
5:00P
INCOMING
3
0045
9/14
5:22P
INCOMING
1
0046
9/14
6:19P
INCOMING
4
0047
9/14
6:49P
INCOMING
1
0048
9/14
6:57P
INCOMING
4
0049
9/14
7:35P
INCOMING
1
0050
9/14
7:40P
NEW YORK
NY
1
0051
9/14
7:42P
INCOMING
3
0052
9/14
7:51P
NEW YORK
NY
1
0053
9/14
7:51P
LOCAL
1
0054
9/14
7:54P
INCOMING
1
0055
9/14
7:54P
INCOMING
3
0056
9/14
7:56P
MIAMI
FL
1
0057
9/14
8:07P
INCOMING
1
0058
9/14
8:15P
INCOMING
1
0059
9/14
8:42P
NEW YORK
NY
2
0060
9/14
8:58P
INCOMING
1
0061
9/14
9:28P
LOCAL
1
0062
9/14
9:28P
NEW YORK
NY
1
0063
9/14
10:03P
NEW YORK
NY
1
0064
9/14
10:04P
LOCAL
1
0065
9/14
10:36P
NEW YORK
NY
2
0066
9/14
11:04P
INCOMING
2
0067
9/15
10:44A
NEW YORK
NY
1
0068
9/15
11:55A
NEW YORK
NY
2
0069
9/15
11:58A
NEW YORK
NY
1
0070
9/15
12:13P
NEW YORK
NY
1
0071
9/15
12:14P
NEW YORK
NY
1
0072
9/15
12:16P
NEW YORK
NY
1
0073
9/15
12:16P
NEW YORK
NY
1
0074
9/15
12:23P
NEW YORK
NY
1
0075
9/15
1:37P
NEW YORK
NY
1
0076
9/15
1:37P
LOCAL
1
0077
9/15
1:45P
INCOMING
2
0078
9/15
2:44P
NEW YORK
NY
1
0079
9/15
2:46P
NEW YORK
NY
1
EFTA00014777

=== Page 12 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 16.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0080
9/15
2:47P
NEW YORK
NY
1
0081
9/15
2:51P
NEW YORK
NY
3
0082
9/15
2:53P
INCOMING
2
0083
9/15
2:55P
NEW YORK
NY
3
0084
9/15
5:28P
INCOMING
1
0085
9/15
5:33P
INCOMING
1
0086
9/15
5:51P
INCOMING
1
0087
9/15
6:18P
INCOMING
1
0088
9/15
6:29P
INCOMING
2
0089
9/15
6:31P
INCOMING
3
0090
9/15
6:42P
INCOMING
2
0091
9/15
6:45P
UN. KINGDO
2
.700
0092
9/15
6:47P
UN. KINGDO
1
.350
.
0093
9/15
6:54P
INCOMING
3
0094
9/15
7:50P
LOCAL
1
0095
9/15
7:51P
MIAMI
FL
1
0096
9/15
8:15P
INCOMING
3
0097
9/15
10:01P
LOCAL
1
0098
9/15
10:14P
MIAMI
FL
1
0099
9/15
10:15P
UN. KINGDO
1
.350
0100
9/15
10:16P
MIAMI
FL
1
0101
9/15
10:47P
F
NEW YORK
NY
NY
1
.25
0102
9/16
8:47A
F
NEW YORK
NY NY
1
.25
0103
9/16
11:45A
INCOMING
10
0104
9/16
11:56A
LOCAL
1
0105
9/16
11:57A
MIAMI
FL
2
0106
9/16
11:58A
INCOMING
3
0107
9/16
12:02P
MIAMI
FL
1
0108
9/16
12:10P
NEW YORK
NY
1
0109
9/16
12:45P
INCOMING
2
0110
9/16
1:11P
INCOMING
2
0111
9/16
1:43P
NEW YORK
NY
2
0112
9/16
1:46P
MOBILE
NY
1
0113
9/16
1:47P
NEW YORK
NY
1
0114
9/16
1:48P
NEW YORK
NY
1
0115
9/16
3:25P
INCOMING
1
0116
9/16
3:37P
INCOMING
1
0117
9/16
4:03P
NEW YORK
NY
3
0118
9/16
4:10P
INCOMING
3
0119
9/16
4:13P
INCOMING
2
0120
9/16
4:23P
INCOMING
1
0121
9/16
4:26P
NEW YORK
NY
1
0122
9/16
5:25P
INCOMING
1
0123
9/16
5:38P
INCOMING
1
0124
9/16
6:35P
LOCAL
1
0125
9/16
7:04P
NEW YORK
NY
1
0126
9/16
7:20P
LOCAL
2
0127
9/16
7:22P
UN. KINGDO
2
.700
0128
9/16
7:42P
LOCAL
2
0129
9/16
7:44P
BETHESDA
DC
1
0130
9/16
8:11P
INCOMING
2
0131
9/16
10:09P
NEW YORK
NY
1
0132
9/16
10:09P
NEW YORK
NY
1
0133
9/16
10:47P
INCOMING
2
0134
9/16
11:14P
UN. KINGDO
1
.350
0135 9/16 11:27P
NEW YORK
NY
1
0136
9/16
11:49P
INCOMING
2
0137
9/17
12:10A
MIAMI
FL
1
0138
9/17
12:11A
LOCAL
1
0139
9/17
1:53A
BETHESDA
DC
3
EFTA00014778

=== Page 13 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 17.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0140 9/17 9:49A
INCOMING
8
0141 9/17 10:05A
INCOMING
1
0142
9/17
10:17A
INCOMING
8
0143
9/17
12:46P
INCOMING
2
0144
9/17
12:59P
INCOMING
1
0145
9/17
1:00P
LOCAL
1
0146
9/17
1:31P
BETHESDA
DC
1
0147
9/17
1:33P
NEW YORK
NY
1
0148
9/17
1:45P
LOCAL
1
0149
9/17
1:46P
BETHESDA
DC
1
0150
9/17
1:47P
INCOMING
1
0151
9/17
2:36P
INCOMING
2
0152
9/17
3:02P
INCOMING
1
0153
9/17
3:30P
INCOMING
2
0154
9/17
3:42P
NEW YORK
NY
2
0155
9/17
3:45P
INCOMING
9
0156
9/17
3:57P
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1
.350
0157
9/17
4:20P
UN. KINGDO
1
.350
0158
9/17
4:21P
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1
.350
0159
9/17
4:22P
INCOMING
1
0160
9/17
4:28P
INCOMING
4
0161
9/17
4:35P
LOCAL
1
0162
9/17
4:36P
CHICAGO
IL
1
0163
9/17
4:42P
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1
.350
0164
9/17
4:43P
UN. KINGDO
4
1.400
0165
9/17
5:04P
INCOMING
3
0166
9/17
5:17P
NEW YORK
NY
1
0167
9/17
6:18P
INCOMING
8
0168
9/17
7:42P
INCOMING
1
0169
9/17
7:51P
LOCAL
2
0170
9/17
8:03P
INCOMING
13
0171
9/17
8:09P
INCOMING
1
0172
9/17
8:17P
NEW YORK
NY
1
0173
9/17
8:19P
INCOMING
2
0174
9/17
8:46P
LOCAL
2
0175
9/17
8:55P
INCOMING
1
0176
9/17
9:09P
INCOMING
3
0177
9/17
10:08P
LOCAL
1
0178
9/17
10:09P
MIAMI
FL
4
0179
9/17
10:18P
BETHESDA
DC
1
0180
9/17
10:45P
INCOMING
1
0181
9/17
10:52P
INCOMING
1
0182
9/17
11:28P
INCOMING
1
0183
9/17
11:33P
INCOMING
2
0184
9/17
11:35P
NEW YORK
NY
1
0185
9/17
11:54P
NEW YORK
NY
1
0186
9/17
11:54P
NEW YORK
NY
1
0187
9/18
12:50A
NEW YORK
NY
1
0188
9/18
12:59A
NEW YORK
NY
2
0189
9/18
1:00A
NEW YORK
NY
1
0190
9/18
10:37A
INCOMING
1
0191
9/18
10:39A
INCOMING
1
0192
9/18
10:58A
INCOMING
3
0193
9/18
11:04A
INCOMING
1
0194 9/18 12:17P
INCOMING
1
0195
9/18
1:12P
INCOMING
7
0196
9/18
1:20P
NEW YORK
NY
2
0197
9/18
1:53P
INCOMING
1
0198
9/18
1:55P
LOCAL
1
0199
9/18
2:57P
INCOMING
8
EFTA00014779

=== Page 14 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 18.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0200
9/18
3:10P
LOCAL
1
0201
9/18
3:17P
INCOMING
1
0202
9/18
4:01P
INCOMING
1
0203
9/18
4:34P
INCOMING
2
0204
9/18
5:37P
NEW YORK
NY NY
11
2.75
0205
9/18
6:28P
NEW YORK
NY NY
1
.25
0206
9/18
7:02P
F F F F
NEW YORK
NY NY
1
.25
0207
9/18
7:15P
NEW YORK
NY NY
2
.50
0208
9/18
7:37P
INCOMING
1
0209
9/18
9:24P
NEW YORK
NY
2
0210
9/18
9:26P
NEW YORK
NY
2
0211
9/18 10:24P
NEW YORK
NY
1
0212
9/19
8:57A
LOCAL
1
0213
9/19 12:02P
INCOMING
12
0214
9/19
12:36P
NEW YORK
NY
3
0215
9/19
1:01P
INCOMING
1
0216
9/19
1:19P
INCOMING
2
0217
9/19
1:56P
LOCAL
1
0218
9/19
:04P
LOCAL
1
0219
9/19
:08P
INCOMING
1
0220
9/19
2:56P
LOCAL
1
0221
9/19
3:10P
INCOMING
3
0222
9/19
4:42P
MOBILE
NY
2
0223
9/19
4:47P
NEW YORK
NY
1
0224
9/19
:19P
INCOMING
1
0225
9/19
:20P
INCOMING
3
0226
9/19
:23P
W PALM BCH FL
2
0227
9/19
:27P
INCOMING
1
0228
9/19
:30P
NEW YORK
NY
1
0229
9/19
:30P
NEW YORK
NY
21
0230
9/19
:32P
INCOMING
1
0231
9/19
:33P
INCOMING
1
0232
9/19
:43P
INCOMING
1
0233
9/19
:07P
INCOMING
1
0234
9/19
8:53P
LOCAL
2
0235
9/19
8:56P
MIAMI
FL
3
0236
9/19
8:59P
NEW YORK
NY
5
0237
9/19
10:40P
NEW YORK
NY
1
0238
9/19
11:24P
NEW YORK
NY
1
0239
9/19
11:24P
NEW YORK
NY
1
0240
9/19
11:27P
NEW YORK
NY
1
0241 9/19 11:28P
MIAMI
FL
1
0242
9/20
1:58A
LOCAL
1
0243
9/20
11:49A
F
NEW YORK
NY NY
1
.25
0244
9/20
11:58A
F
NEW YORK
NY NY
6
1.50
0245
9/20
12:39P
INCOMING
1
0246
9/20
1:59P
NEW YORK
NY
1
0247
9/20
:12P
INCOMING
1
0248
9/20
:30P
INCOMING
6
0249
9/20
2:36P
LOCAL
1
0250
9/20
4:19P
INCOMING
7
0251
9/20
6
:24P
F
NEW YORK
NY NY
3
.75
0252
9/20
6:27P
F
NEW YORK
NY NY
19
4.75
0253
9/20
6:55P
MIAMI
FL
9
0254
9/20
7:06P
MIAMI
FL
1
0255
9/20
7:07P
LOCAL
1
0256
9/20
7:07P F
NEW YORK
NY NY
1
.25
0257
9/20
7:08P
LOCAL
2
0258
9/20
7:10P
NEW YORK
NY
1
0259
9/20
7:14P
NEW YORK
NY
1
EFTA00014780

=== Page 15 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 19.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0260
9/20
7:22P
NEW YORK
NY
1
0261
9/20
7:28P
NEW YORK
NY
1
0262
9/20
8:54P
LOCAL
1
0263
9/20
8:57P
INCOMING
1
0264
9/20
15P
LOCAL
1
0265
9/20
INCOMING
2
0266
9/20
9:38P
INCOMING
1
0267
9/20
9:43P
CHICAGO
IL
1
0268
9/20
9:43P
CHICAGO
IL
1
0269
9/20
10:25P
INCOMING
2
0270
9/20
10:34P
NEW YORK
NY
1
0271
9/20
LOCAL
2
0272
9/20
10
D
NEW YORK
NY
3
0273
9/20
MOBILE
NY
1
0274
9/20
NEW YORK
NY
1
0275
9/20
INCOMING
1
0276
9/20
25P
NEW YORK
NY
1
0277
9/20
11
NEW YORK
NY
1
0278
20
11
53P
MOBILE
NY
1
0279
38A
NEW YORK
NY
1
0280
30P
****
NEW YORK
NY NY
1
.25
0281
NEW YORK
NY NY
2
.50
0282
9/21
NEW YORK
NY NY
2
.50
0283
INCOMING
2
0284
INCOMING
1
0285
9/21
NEW YORK
NY
1
0286
9/21
3:45P
LOCAL
1
0287
9/21
3:46P
NEW YORK
NY
1
0288
9/21
3:56P
INCOMING
1
0289
9/21
4:06P
MOBILE
NY
4
0290
9/21
4:10P
UN. KINGDO
1
.350
0291
9/21
4:16P
NEW YORK
NY
2
0292
9/21
5:42P
NEW YORK
NY NY
2
0293
9/21
6:07P
NEW YORK
NY NY
1
0294
9/21
6:28P
NEW YORK
NY NY
2
0295
9/21
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NEW YORK
NY NY
1
0296
9/21
16P
NEW YORK
NY NY
1
0297
9/21
7:20P
NEW YORK
NY NY
1
0298
9/21
7:21P
NEW YORK
NY NY
24
6.00
0299
9/21
01P
NEW YORK
NY
NY
4
1.00
0300
9/21
8:38P
NEW YORK
NY NY
8
0301
9/21
9:26P
NEW YORK
NY NY
9
0302
8:03A
NEW YORK
NY NY
1
0303
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NEW YORK
NY NY
2
0304
10:12A
NEW YORK
NY NY
15
3.75
0305
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NY
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0306
1
29A
NEW YORK
NY
NY
1
0307
1
13P
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NY
NY
6
1.50
GUNU
0308
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NY
NY
2
0309
08P
NEW YORK
NY
1
0310
9/22
10P
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4
0311
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INCOMING
3
0312
58P
INCOMING
1
0313
:59P
CHARLT AML VI
1
0314
P
C ST CROIX VI
1
0315
P
NEW YORK
NY
1
0316
9
P
LOCAL
1
0317
9
14P
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NY
2
0318
3:28P
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1
0319
9
4:07P
LOCAL
1
EFTA00014781

=== Page 16 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 20.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0320
9/22
4:23P
F
NEW YORK
NY NY
1
.25
0321
9/22
4:25P
NEW YORK
NY NY
1
0322
9/22
4:46P
NEW YORK
NY NY
2
.50
0323
4:48P
NEW YORK
NY NY
4
1.00
4:52P
NEW YORK
NY
NY
1
33P
F
NEW YORK
NY
NY
1
5
34P
NEW YORK
NY
NY
2
0
35P
F
NEW YORK
NY
NY
2
0
39P
NEW YORK
NY
NY
1
NEW YORK
NY
NY
3
NEW YORK
NY
NY
2
NNUNNUUNNOUNN
57P
NEW YORK
NY
NY
1
12P
NEW YORK
NY NY
1
33P
INCOMING
12P
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5
53P
NEW YORK
NY NY
1
9
:55P F
NEW YORK
NY NY
1
0337
10
07P
NEW YORK
NY
NY
0338
10:27P
NEW YORK
NY
NY
1
0339
10:28P
0341
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F F F F
NEW YORK
NY
NY
1
NNNNNN
0340
1:02P
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NY NY
NEW YORK
NY
0342
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NEW YORK
NY
NY
0343
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NY
NY
5
0344
9
58A
NEW YORK
NY NY
1
0345
10
06A
NEW YORK
NY
NY
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0346
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NEW YORK
NY
NY
1
0347
12:18P
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NY
NY
1
0348
1
49P
NEW YORK
NY
NY
5
2.00 5.75 1.25 1.75 1.25
0349
53P
NEW YORK
NY
NY
23
0350
58P
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NY
NY
1
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0351
34P
C ST CROIX
VI
4
0352
37P
INCOMING
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0353
38P
BETHESDA
DC
2
0354
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1
0355
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NY
1
0356
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0357
54P
LOCAL
1
0358
55P
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NY
1
0359
56P
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NY
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NY
NY
3
0361
19P
NEW YORK
NY NY
1
0362
48P
NEW YORK
NY NY
1
0363
28P
NEW YORK
NY
0364
44P
NEW YORK
NY
2
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6
16P
NEW YORK
NY
NY NY NY NY NY
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0366
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41P
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NY
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22P
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NY
3
0368
02P
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NY
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1.25 1.50 .75 .25 overnon
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NY
NY
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0370
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28P
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NY
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41P
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NY
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NEW YORK
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0376
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0377
12
7A
NEW YORK
NY
NY
.25
0378
24
9
39A
NEW YORK
NY
NY
12
3.00
0379
9/24
10:13A
NEW YORK
NY
NY
1
.25
EFTA00014782

=== Page 17 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 21.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0380
9/24
11:09A
F
NEW YORK
NY NY
1
.25
0381
9/24
11:10A
F
NEW YORK
NY NY
1
.25
0382
9/24
11:32A
F
NEW YORK
NY NY
1
.25
0383
9/24
11:35A
F
NEW YORK
NY NY
10
2.50
0384
9/24
12:03P
BETHESDA
DC
1
0385
9/24
12:05P
0386
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mm
NEW YORK
NY NY
4
1.00
9/24
NEW YORK
NY NY
1
.25
0387
9/24
2:27P
MIAMI
FL
3
0388
9/24
2:54P
F
TT
NEW YORK
NY NY
1
.25
0389
9/24
3:50P
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NY NY
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.50
0390
9/24
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NY
1
0391
9/24
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DC
3
0392
9/24
4:10P
F
NEW YORK
NY NY
3
.75
0393
9/24
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0394
9/24
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0395
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NEW YORK
NY
2
0396
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LOCAL
1
0397
9/24
5:37P
S
ITALY
1
0398
9/24
5:59P
LOCAL
1
0399
9/24
7:46P
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NY
1
0400
9/24
7:48P
NEW YORK
NY
1
0401
9/24
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0402
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NEW YORK
NY
1
0403
9/24
7:56P
MOBILE
NY
1
0404
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NY
7
0405
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NY
2
0406
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DC
2
0407
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1
0408
9/24
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NY
1
0409
9/24
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FL
3
0410
9/24
8:19P
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2
0411
9/24
9:03P
LOCAL
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0412
9/24
9:03P
INCOMING
1
0413
9/24
9:04P
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4
0414
9/24
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LOCAL
1
0415
9/24
9:09P
BETHESDA
DC
2
0416
9/24
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NEW YORK
NY
7
0417
9/24
9:21P
NEW YORK
NY
1
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9/24
9:23P
800 SERV.
2
0419
9/24
10:48P
INCOMING
1
0420
9/24
11:52P
S
W PALM BCH FL
1
0421
9/24
11:53P
MOBILE
NY
4
0422
9/25
12:01A
MIAMI
FL
1
0423
9/25
12:10A
800 SERV.
6
0424
10:37A
INCOMING
FL
1
0425
1
:25A
TT
F
W PALM BCH FL NY
2
.50
0426
2:41P
W PALM BCH FL NY
3
.75
0427
9/25
4:58P
INCOMING
FL
3
0428
9/25
5:54P
INCOMING
FL
2
0429
9/25
6:19P
INCOMING
FL
1
0430
9/26
9:31A
INCOMING
FL
1
0431
11:19A
INCOMING
FL
2
0432
9/26
12:55P
INCOMING
FL
7
0433
9/26
1:43P
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FL
1
0434
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1:43P
DELRAY BEA
FL
FL
1
0435
9
26
1:46P
NEW YORK
NY FL
2
0436
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1:48P
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FL
1
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9
26
1:52P
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FL
FL
1
0438
2:15P
INCOMING
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9
0439
9/26
2:27P
BETHESDA
DC FL
1
EFTA00014783

=== Page 18 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 22.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0440
9/26
2:35P
UN. KINGDO
FL
2
.700
0441
9/26
4:15P
INCOMING
FL
1
0442
9/26
4:16P
NEW YORK
NY
FL
2
0443
9/26
4:31P
INCOMING
FL
4
0444
9/26
4:41P
UN. KINGDO
FL
2
.700
-
0445
9/26
4:44P
NEW YORK
NY
FL
2
0446
9/26
4:51P
INCOMING
FL
1
0447
9/26
4:58P
NEW YORK
NY
FL
1
0448
9/26
5:01P
INCOMING
FL
6
0449
9/26
:05P
W
INCOMING
FL
1
0450
9/26
:09P
BETHESDA
DC
FL
3
0451
9/26
10P
W
INCOMING
FL
2
0452
9/26
:12P
NEW YORK
NY
FL
2
0453
9/26
13P
NEW YORK
NY
FL
3
0454
9/26
16P
INCOMING
FL
0455
9/26
19P
INCOMING
FL
0456
9/26
30P
INCOMING
FL
1
0457
9/26
30P
NEW YORK
NY
FL
1
0458
9/26
31P
NEW YORK
NY FL
2
0459
9/26
:33P
WEST PALM
FL FL
1
0460
9/26
:33P
QUEENS
NY FL
0461
9/26
:35P
RUTHERFORD NJ FL
2
0462
9/26
37P
WEST PALM
FL
FL
1
0463
9/26
38P
NEW YORK
NY FL
1
0464
9/26
:39P
W
INCOMING
FL
1
0465
9/26
:39P
QUEENS
NY FL
1
0466
9/26
5:39P
INCOMING
FL
1
0467
9/26
5:41P
INCOMING
FL
1
0468
9/26
:55P
INCOMING
FL
1
0469
9/26
5:59P
INCOMING
FL
7
0470
9/26
6:10P
NEW YORK
NY
FL
1
0471
9/26
:13P
NEW YORK
NY FL
3
0472
9/26
16P
BETHESDA
DC FL
3
0473
9/26
6:18P
NEW YORK
NY
FL
1
0474
9/26
6
24P
INCOMING
FL
1
0475
9/26
:28P
INCOMING
FL
1
0476
9/26
6:56P
INCOMING
FL
3
0477
9/26
7:03P
INCOMING
FL
1
0478
9/26
7:24P
C ST CROIX VI FL
2
0479
9/27
11:26A
DELRAY BCH FL FL
1
0480
9/27
11:28A
DELRAY BEA FL FL
1
0481
9/27
11:28A
NEW YORK
NY
FL
1
0482
9/27
6A
INCOMING
FL
1
0483
9/27
7A
INCOMING
FL
1
0484
9/27
11
8A
DELRAY BEA FL
FL
0485
9/27
11:39A
MOBILE
FL
2
0486
9/27
39A
W
INCOMING
FL
1
0487
9/27
:41A
INCOMING
FL
0488
9/27
:42A
INCOMING
FL
0489
9/27
12:00P
INCOMING
FL
1
0490
9/27
12:00P
INCOMING
FL
1
0491
9/27
12:01P
INCOMING
FL
0492
9/27
12:08P
INCOMING
FL
3
0493
9/27
P
NEW YORK
NY FL
1
0494
9/27
P
WEST PALM
FL FL
1
0495
9/27
12:13P
NEW YORK
NY FL
1
0496
9/27
WEST PALM
FL FL
2
0497
9/27
47P
INCOMING
FL
4
0498
9/27
2:27P
INCOMING
FL
5
0499
9/27
3:04P
NEW YORK
NY
FL
1
EFTA00014784

=== Page 19 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE NUMBER BILL DATE PAGE 23.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0500
9/27
3:05P
NEW YORK
NY FL
3
0501
9/27
4:38P
NEW YORK
NY
FL
1
0502
9/27
4:39P
BETHESDA
DC
FL
1
0503
9/27
6:19P
NEW YORK
NY
FL
1
0504
9/27
6:31P
MOBILE
FL
1
0505
9/27
6:34P
W PALM BCH FL
FL
1
0506
9/27
6:37P
MOBILE
FL
1
0507
9/27
MOBILE
FL
2
0508
9/27
INCOMING
FL
2
0509
9/27
8:19P
NEW YORK
NY
FL
2
0510
9/27
8:21P
NEW YORK
NY
FL
4
0511
9/27
8:25P
INCOMING
FL
6
0512
9/27
8:31P
INCOMING
FL
3
0513
9/27
INCOMING
FL
8
0514
9/27
NEW YORK
NY
FL
1
0515
9/27
BETHESDA
DC FL
2
0516
9/27
53P
QUEENS
NY FL
1
0517
9:12P
WILTON
CT FL
1
0518
9:29P
MOBILE
FL
1
9
37A
NEW YORK
NY FL
1
0520
8:53A
MOBILE
FL
2
0521
9:57A
INCOMING
FL
4
0522
1
4A
INCOMING
FL
6
0523
10:38A
W
INCOMING
FL
3
0524
1
01A
WEST PALM
FL
FL
3
0525
28
1:53P
INCOMING
FL
8
0526
28
2:03P
NEW YORK
NY FL
2
0527
9/28
2:05P
INCOMING
FL
1
0528
2:06P
INCOMING
FL
1
0529
3:25P
INCOMING
FL
2
0530
INCOMING
FL
1
0531
4:24P
INCOMING
FL
1
0532
9:34P
NEW YORK
NY FL
1
0533
9:35P
NEW YORK
NY FL
1
0534
9:38P
NEW YORK
NY FL
2
0535
9:40P
NEW YORK
NY FL
1
0536
9:46A
NEW YORK
NY FL
2
0537
NEW YORK
NY FL
4
0538
10:17A
WEST PALM
FL FL
2
0539
10:18A
NEW YORK
NY FL
1
0540
9/29
10:
20A
S
NEW YORK
NY FL
1
0541
10:
1A
NEW YORK
NY FL
2
0542
9/29
3A
NEW YORK
NY FL
1
0543
9/29
4A
NEW YORK
NY FL
3
0544
45A
QUEENS
NY FL
1
0545
NEW YORK
NY FL
1
0546
W
INCOMING
FL
1
0547
47A
NEW YORK
NY FL
3
0548
9/29
:09A
NEW YORK
NY FL
0549
:12A
WEST PALM
FL FL
2
0550
12:35P
INCOMING
FL
1
0551
:18P
NEW YORK
NY FL
2
0552
3:23P
NEW YORK
NY FL
0553
INCOMING
FL
3
0554
P
NEW YORK
NY
FL
1
0555
NEW YORK
NY FL
1
0556
9
NEW YORK
NY FL
0
7
20P
INCOMING
FL
3
0
8
28P
NEW YORK
NY FL
1
0559
9
05P
BETHESDA
DC FL
2
EFTA00014785

=== Page 20 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 24.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0560
9/29
6:17P
INCOMING
FL
11
0561
9/29
6:39P
INCOMING
FL
4
0562
6:52P
UN. KINGDO
FL
3
1.050
0563
9/29
7:01P
UN. KINGDO
FL
1
.350
0564
9/29
7:09P
UN. KINGDO
FL
5
1.750
0565
9/29
7:15P
800 SERV.
FL
2
0566
9/29
7:20P
NEW YORK
NY
FL
1
0567
9
7:29P
QUEENS
NY
FL
1
0568
7:32P
INCOMING
FL
1
0569
9/29
7:34P
INCOMING
FL
2
0570
9/29
7:36P
800 SERV.
FL
2
0571
9/29
7:43P
BETHESDA
DC
FL
2
0572
7:56P
NEW YORK
NY
FL
1
0573
9/29
8:16P
INCOMING
FL
12
0574
9/29
8:17P
n
INCOMING
FL
1
0575
9/29
8:39P
NEW YORK
NY
FL
2
0576
9/29
9:34P
NEW YORK
NY
FL
1
0577
9/29
9:35P
BROOKLYN
NY
FL
2
0578
9/29
9:36P
INCOMING
FL
5
0579
9/29
9:40P
W
INCOMING
FL
1
0580
9/29
9:40P
WEST PALM
FL
FL
2
0581
9/29
9:42P
BROOKLYN
NY FL
1
0582
9/29
9:42P
BETHESDA
DC FL
2
0583
29
9:44P
NEW YORK
NY
FL
1
0584
9/29
11:51P
LOCAL
2
0585
9/30
12:02A
LOCAL
3
0586
9/30
12:11A
NEW YORK
NY
2
0587
9/30
12:14A
NEW YORK
NY
1
0588
30
12:19A
MOBILE
NY
2
0589
9/30
12:21A
UN. KINGDO
.350
0590
9/30
12:36A
INCOMING
8
0591
9/30
6:45A
UN. KINGDO
1
.350
0592
9/30
7:03A
UN. KINGDO
3
1.050
0593
9/30
7:13A
MOBILE
NY
1
0594
9/30
7:23A
INCOMING
3
0595
9/30
7:31A
INCOMING
6
0596
9/30
7:37A
MOBILE
NY
1
0597
9/30
7:39A
INCOMING
2
0598
9/30
8:24A
UN. KINGDO
4
1.400
0599
9/30
8:28A
AUSTRIA
1
.350
0600
9/30
8:29A
UN. KINGDO
1
.350
0601
9/30
8:44A
W PALM BCH FL
3
0602
9/30
8:49A
INCOMING
2
0603
9/30
8:55A
NEW YORK
NY
2
0604
9/30
8:58A
NEW YORK
NY
1
0605
9/30
9:01A
W PALM BCH
FL
1
0606
9/30
9:02A
NEW YORK
NY
4
0607
9/30
1:03P
LDUN. KINGDO
NY
.350
0608
9/30
1:45P
LDUN. KINGDO
NY
1.050
0609
9/30
1:49P
LDUN. KINGDO
NY
1.400
0610
9/30
1:58P
LDUN. KINGDO
NY
2.800
0611
9/30
2:23P
LDUN. KINGDO
NY
1.750
0612
9/30
2:28P
LDUN. KINGDO
NY
.350
0613
9/30
2:49P
LDUN. KINGDO
NY
.350
0614
9/30
6:56P
LDUN. KINGDO
NY
.350
0615
9/30
6:56P
LDUN. KINGDO
NY
.350
0616
30
6:57P
LDUN. KINGDO
NY
.350
0617
9/30
9:39P
LDUN. KINGDO
NY
4.900
0618
9/30
9:44P
LDUN. KINGDO
NY
.350
0619
10/01
5:54A
LDUN. KINGDO
NY
4.900
EFTA00014786

=== Page 21 ===
ACCOUNT NAME
ACCOUNT
NUMBER
BILL DATE PAGE 25.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0620
10/01
6:51A
NCOMNG LDUN. KINGDO
NY
.700
0621
10/01
8:38A
NCOMNG LDUN. KINGDO
NY
.350
0622
10/01
8:56A
NCOMNG LDUN. KINGDO
NY
.350
0623
10/01
8:59A
NCOMNG LDUN. KINGDO
NY
.700
0624
10/01
9:32A
NCOMNG LDUN. KINGDO
NY
.350
0625
10/01
9:37A
NCOMNG LDUN. KINGDO
NY
.350
0626
10/01
11:40A
INCOMNG LDUN.
KINGDO
NY
1.050
0627
10/01
1:04P
INCOMNG LDUN. KINGDO
NY
.700
0628
10/01
1:59P
INCOMNG LDUN. KINGDO
NY
.350
0629
10/01
2:38P
NCOMNG LDUN. KINGDO
NY
2.800
0630
10/01
2:58P
INCOMNG LDUN. KINGDO
NY
.350
0631
10/01
5:00P
NCOMNG LDUN. KINGDO
NY
.350
0632
10/01
6:37P
NCOMNG LDUN. KINGDO
NY
2.800
0633
10/01
7:14P
INCOMNG LDUN.
KINGDO
NY
.700
0634
10/02
6:38A
NCOMNG LDUN. KINGDO
NY
1.050
0635
10/02
11:43A
INCOMNG LDUN. KINGDO
NY
.350
0636
10/02
12:20P
NCOMNG LDUN. KINGDO
NY
.350
0637
10/02
12:41P
INCOMNG LDUN. KINGDO
NY
.350
0638
10/02
12:44P
INCOMNG LDUN.
KINGDO
NY
.350
0639
10/02
12:46P
NCOMNG LDUN. KINGDO
NY
.350
0640
10/02
12:57P
INCOMNG LDUN. KINGDO
NY
.700
0641
10/02
1:58P
INCOMNG LDUN. KINGDO
NY
1.750
0642
10/02
3:05P
INCOMNG LDUN. KINGDO
NY
.350
0643
10/02
3:08P
NCOMNG LDUN.
KINGDO
NY
.700
0644
10/02
9:40P
INCOMNG LDUN. KINGDO
NY
.700
0645
10/03
10:57A
NCOMNG LDUN. KINGDO
NY
1.050
0646
10/03
11:03A
NCOMNG LDUN. KINGDO
NY
1.050
0647
10/03
11:20A
INCOMNG LDUN. KINGDO
NY
1.400
0648
10/03
11:26A
INCOMNG LDUN. KINGDO
NY
.700
0649
10/03
1:44P
NCOMNG LDUN. KINGDO
NY
.350
0650
10/03
1:46P
INCOMNG LDUN. KINGDO
NY
.350
0651
10/03
2:18P
INCOMNG LDUN. KINGDO
NY
1.400
0652
10/03
4:29P
NCOMNG LDUN.
KINGDO
NY
.350
0653
10/03
4:44P
NCOMNG LDUN. KINGDO
NY
.350
0654
10/03
5:00P
NCOMNG LDUN. KINGDO
NY
1.400
0655
10/03
5:06P
INCOMNG LDUN. KINGDO
NY
2.800
0656
10/03
6:02P
NCOMNG LDUN. KINGDO
NY
.350
0657
10/04
10:25A
NCOMNG LDUN.
KINGDO
NY
.350
0658
10/04
10:45A
NCOMNG LDUN. KINGDO
NY
.350
0659
10/04
11:13A
NCOMNG LDUN. KINGDO
NY
.350
0660
10/04
11:14A
INCOMNG LDUN.
KINGDO
NY
.350
0661
10/04
11:20A
NCOMNG LDUN. KINGDO
NY
.350
0662
10/04
11:20A
NCOMNG LDUN. KINGDO
NY
1.400
0663
10/04
12:52P
INCOMNG LDUN. KINGDO
NY
.350
0664
10/04
12:53P
INCOMNG LDUN. KINGDO
NY
1.050
0665
10/05
10:47A
NCOMNG LDUN. KINGDO
NY
.350
0666
10/05
11:27A
NCOMNG
LDUN.
KINGDO
NY
.700
0667
10/05
12:24P
NCOMNG LDUN.
KINGDO
NY
.350
0668
10/05
12:25P
INCOMNG LDUN. KINGDO
NY
1.050
0669
10/05
1:33P
INCOMNG LDUN. KINGDO
NY
1.400
0670
10/05
3:30P
INCOMNG LDUN. KINGDO
NY
1.400
0671
10/05
6:18P
INCOMNG LDUN.
KINGDO
NY
.700
0672
10/06
5:50A
NCOMNG LDUN. KINGDO
NY
1.750
0673
10/06
7:46A
NCOMNG LDUN. KINGDO
NY
1.750
0674
10/06
9
:36A
NCOMNG LDUN. KINGDO
NY
.350
0675
10/06
9:43A
INCOMNG LDUN.
KINGDO
NY
1.400
0676
10/06
9:59A
INCOMNG LDUN. KINGDO
NY
.350
0677
10/06
11:48A
NCOMNG LDUN. KINGDO
NY
.700
0678
10/06
12:04P
NCOMNG LDUN. KINGDO
NY
.350
0679
10/06
1:11P
NCOMNG LDUN. KINGDO
NY
.700
EFTA00014787

=== Page 22 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 26.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0680
10/06
3:14P
INCOMNG LDUN. KINGDO
NY
.350
0681
10/06
3:34P
INCOMNG LDUN. KINGDO
NY
2.800
0682
10/06
6:20P
INCOMNG LDUN. KINGDO
NY
.350
0683 10/07 10:20A
INCOMNG LDUN. KINGDO
NY
1.050
0684
10/07
11:24A
INCOMNG LDUN. KINGDO
NY
.350
0685
10/07
12:55P
INCOMNG LDUN. KINGDO
NY
1.050
0686
10/07
1:44P
INCOMNG LDUN. KINGDO
NY
.350
0687
10/08
9:43A
INCOMNG LDUN. KINGDO
NY
.350
0688
10/08
10:25A
INCOMNG LDUN. KINGDO
NY
1.400
0689
10/08
6:55P
RETRIEVAL
LOCAL
3
0690
10/08
6:57P
UN. KINGDO
1
.350
0691
10/08
6:58P
NEW YORK
NY
0692
10/08
7:14P
INCOMING
2
0693
10/08
7:16P
MOBILE
NY
2
0694
10/08
7:19P
BETHESDA
DC
1
0695
10/08
7:20P
NEW YORK
NY
1
0696
10/08
7:42P
NEW YORK
NY
1
0697
10/08
7:43P
NEW YORK
NY
1
0698
10/08
7:44P
MOBILE
NY
1
0699
10/08
7:45P
LOSANGELES
CA
1
0700
10/08
7:48P
MOBILE
NY
0701
10/08
7:49P
CHICAGO
IL
3
0702
10/09
45A
F
NEW YORK
NY
NY
1
0703
10/09
10
27A
F
NEW YORK
NY
NY
5
1.25
0704
10/09
10
54A
F
NEW YORK
NY
NY
0705
10/09
11
07A
F
NEW YORK
NY
NY
0706
10/09
<<<<<<<<
50
11 33A F
NEW YORK
NY
NY
2
.50
0707
10/09
41A
F
NEW YORK
NY
NY
1
0708
10/09
12:00P F
NEW YORK
NY
NY
0709
10/09
:06P
F
NEW YORK
NY
NY
2
0
0710
10/09
12:07P
F
NEW YORK
NY
NY
2
0711
10/09
12:09P
F
NEW YORK
NY
NY
0712
10/09
12:38P
NEW YORK
NY
3
0713
10/09
12:42P
INCOMING
2
0714
10/09
12:45P
INCOMING
3
0715
10/09
1:01P
NEW YORK
NY
3
0716
10/09
1:04P
NEW YORK
NY
1
0717
10/09
1:05P
NEW YORK
NY
1
0718
10/09
1:12P
INCOMING
3
0719
10/09
2:24P
INCOMING
1
0720
10/09
2:24P
INCOMING
2
0721
10/09
2:27P
INCOMING
2
0722
10/09
4:15P
INCOMING
2
0723
10/09
4:42P
INCOMING
1
0724
10/09
5:32P
LOCAL
1
0725
10/09
5:58P
LOCAL
2
0726
10/09
5:59P
BEVERLYHLS
1
0727
10/09
6:00P
BEVERLYHLS
1
0728
10/09
6:02P
INCOMING
0729
10/09
6:15P
NEW YORK
0730
10/09
NY NY NY NY NY NY NY VI AA CA FL CA
1
6:15P
NEW YORK
1
0731
10/09
6:17P
NEW YORK
3
0732
10/09
6:56P
INCOMING
0733
10/09
7:15P
INCOMING
0734
10/09
7:21P
NEW YORK
0735
10/09
7:22P
NEW YORK
0736
10/09
7:23P
NEW YORK
0737
10/09
7:24P
W PALM BCH
0738
10/09
7:25P
C ST CROIX
1
0739
10/09
7:26P
MOBILE
1
EFTA00014788

=== Page 23 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE
PAGE
27.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0740
10/09
7:46P
NEW YORK
NY
1
0741
10/09
7:47P
NEW YORK
NY
1
0742
10/09
7:47P
NEW YORK
NY
1
0743
10/09
7:48P
LOCAL
1
0744
10/09
8:51P
INCOMING
1
0745
10/09
9:31P
LOCAL
0746
10/09
9:31P
NEW YORK
NY
2
0747
10/09
9:33P
NEW YORK
NY
1
0748
10/09
9:36P
NEW YORK
NY
1
0749
10/09
9:37P
INCOMING
1
0750
10/09
9:39P
INCOMING
0751
10/10
8:21A
LOCAL
0752
10/10
8:21A
NEW YORK
NY
0753
10/10
8:22A
NEW YORK
NY
1
0754
10/10
8:22A
W PALM BCH
FL
2
0755
10/10
8:54A
F
NEW YORK
NY NY
2
.50
0756
10/10
9:24A
INCOMING
5
0757
10/10
9:27A
INCOMING
1
0758
10/10
9:34A
LOCAL
3
0759
10/10
10:00A
BETHESDA
DC
2
0760
10/10
10:02A
BETHESDA
DC
4
0761
10/10
10:10A
mr
NEW YORK
NY NY
2
.50
0762
10/10
10:22A
NEW YORK
NY
4
0763
10/10
10:33A
NEW YORK
NY
1
0764
10/10
10:35A
NEW YORK
NY
2
0765
10/10
10:36A
NEW YORK
NY
1
0766
10/10
10:45A
NEW YORK
NY
4
0767
10/10
10:49A
NEW YORK
NY
0768
10/10
10:50A
NEW YORK
NY
5
0769
10/10
10:54A
NEW YORK
NY
0770
10/10
10:55A
LOCAL
2
0771
10/10
10:59A
W PALM BCH FL
0772 10/10 11:06A
MOBILE
NY
0773
10/10
11:42A
INCOMING
3
0774
10/10
11:45A
NEW YORK
NY
1
0775
10/10
12:13P
NEW YORK
NY
1
0776
10/10
12:32P
INCOMING
0777
10/10
12:46P
MOBILE
NY
0778
10/10
12:47P
NEW YORK
NY
2
0779
10/10
12:54P
INCOMING
3
0780
10/10
2:07P
INCOMING
5
0781
10/10
2:36P
BETHESDA
DC
1
0782
10/10
2:46P
NEW YORK
NY
0783
10/10
2:49P
INCOMING
2
0784
10/10
2:51P
INCOMING
0785
10/10
2:57P
INCOMING
3
0786
10/10
3:12P
INCOMING
1
0787
10/10
3:22P
INCOMING
1
0788
10/10
4:17P
MOBILE
NY
0789
10/10
4:17P
NEW YORK
NY
1
0790
10/10
4:24P
INCOMING
0791
10/10
5:59P
LOCAL
0792
10/10
6:21P
10/10
8:08P E
NEW YORK
NY NY
2
.50
0793
NEW YORK
NY NY
6
1.50
0794
10/10
8:55P
W PALM BCH
FL
1
0795
10/10
9:27P
NEW YORK
NY
1
0796
10/10
9:30P
NEW YORK
NY
0797
10/10
9:31P
NEW YORK
NY
2
0798
10/10
9:40P F
NEW YORK
NY NY
1
.25
0799
10/10
9:55P
MOBILE
NY
1
EFTA00014789

=== Page 24 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 28.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0800 10/10 10:01P
NEW YORK
NY
2
0801
10/10
10:10P
MOBILE
NY
1
0802
10/10
10:18P
MIAMI
FL
0803
10/10
10:18P
MIAMI
FL
0804
10/10
10:19P
MOBILE
NY
0805
10/10
10:20P
NEW YORK
NY
2
0806
10/10
10:21P
E
NEW YORK
NY
NY
.25
0807
10/10
10:22P
MOBILE
NY
0808
10/10
10:23P
NEW YORK
NY
0809
10/10
10:35P
NEW YORK
NY
0810
10/10
11:10P
INCOMING
3
0811
10/10
11:30P
NEW YORK
NY NY
3
.75
0812
10/10
B
NEW YORK
NY NY
2
.50
0813
10/10
NEW YORK
NY
0814
10/10
NEW YORK
NY
0815
10/10
MOBILE
NY
0816
10/11
NEW YORK
NY
0817
10/11
12:59P
LOSANGELES
CA
FL
0818
10/11
1:00P
LOSANGELES
CA
FL
0819
10/11
1:00P
NEW YORK
NY
FL
0820
10/11
1:01P
NEW YORK
NY FL
0821
10/11
1:02P
UN. KINGDO
FL
.350
0822
10/11
3:11P
NEW YORK
NY
FL
2
0823
10/11
3:12P
NEW YORK
NY
FL
0824
10/11
3:33P
MOBILE
FL
2
0825
10/11
6:30P
NEW YORK
NY
FL
0826
10/11
6:32P
NEW YORK
NY
FL
9
0827
10/11
INCOMING
FL
0828
10/12
0829
12:52P 11:01P 12:03P
9:32A
NEW YORK
NY
FL
10/12
WEST PALM
FL
FL
0830
10/12
INCOMING
FL
0831
10/12
1:05P
INCOMING
FL
2
0832
10/12
1:39P
INCOMING
FL
2
0833
10/12
2:15P
WEST PALM
FL
FL
0834
10/12
2:22P
NEW YORK
NY
FL
0835
10/12
2:22P
MIAMI
FL
FL
0836
10/12
2:27P
INCOMING
FL
0837
10/12
2:27P
INCOMING
FL
0838
10/12
5:08P
NEW YORK
NY
FL
0839
10/12
5:56P
NEW YORK
NY
FL
0840
10/12
5:57P
NEW YORK
NY
FL
2
0841
10/12
6:29P
NEW YORK
NY
FL
0842
10/12
6:59P
NEW YORK
NY
FL
0843
10/12
8:59P
NEW YORK
NY FL
0844
10/12
8:59P Й
INCOMING
FL
0845
10/12
9:01P
NEW YORK
NY
FL
0846
10/12
9:02P
NEW YORK
NY
FL
0847
10/12
9:03P
LOSANGELES
CA
FL
0848
10/12
9:30P
NEW YORK
NY
FL
0849
10/12
9:31P
NEW YORK
NY
FL
EFTA00014790

=== Page 25 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 29.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0850 10/12 9:55P
LOSANGELES CA FL
2
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
1640
90.50
91.00
CALL CHARACTERISTICS:
F = Call Forwarding, D = AT&T Connect Calls,
S = Long Distance Service Billed Separately, W = Call Waiting,
A = Automatic Dropped Call Credit
"CALLS FROM" KEY:
NY = NEW YORK, FL = FLORIDA
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001
9/13
1:03P
.00
0002
9/17
8:18P
.00
0003
9/19
1:02A
.00
0004
9/19
1:50P
.00
0005
9/19
2:58P
0000-000000
.00
0006
9/21
6:47P
.00
0007 9/21 9:19P
.00
0008
9/23
12:46P
.25
0009 9/24 3:57P
.25
0010
9/27
8:22P
.00
0011
9/27
8:48P
.00
0012
9/27
9:46P
.00
0013 9/27 9:49P
.00 0014 9/28 2:17P
.00
0015 9/29 10:32A
.00 0016 9/29 12:14P
.00
0017 9/29 6:41P
.00 0018 10/09 6:56P
.00
0019 10/10 2:06P
.00 0020 10/10 10:06P
.00
0021 10/10 10:42P
.00 0022 10/12 6:32P
.00
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.50
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: GREAT BRITAIN,
0001 9/30 12:00A
CALL SVC
1
.99
0002 9/30 5:50P
INTL NTWK
1
.99
.35
0003 9/30 9:15P
INTL NTWK
2
1.98
.70
0004 10/01 12:00A
CALL SVC
1
.99
0005 10/01 6:21P
INTL NTWK
.99
.35
0006 10/01 8:58P
INTL NTWK
1
.99
.35
0007 10/01 8:59P
INTL NTWK
1
.99
.35
0008 10/01 10:20P
INTL NTWK
3
2.97
1.05
0009 10/01 10:23P
INTL NTWK
1
.99
.35
0010 10/01 10:24P
INTL NTWK
1
.99
.35
0011 10/01 11:48P
INTL NTWK
1
.99
.35
0012 10/01 11:48P
INTL NTWK
1
.99
.35
EFTA00014791

=== Page 26 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 30.0
JEFFREY E EPSTEIN &
OCT 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0013 10/01 11:50P
INTL NTWK
3
2.97
1.05
0014 10/02 9:17A
INTL NTWK
2
1.98
.70
0015 10/03 12:00A
CALL SVC
1
.99
0016 10/03 12:26A
INTL NTWK
3
2.97
1.05
0017 10/03
3:44P
INTL NTWK
7
6.93
2.45
0018 10/03 7:25P
INTL NTWK
1
.99
.35
0019 10/04 11:37P
INTL NTWK
1
.99
.35
0020 10/05 2:58P
INTL NTWK
3
2.97
1.05
0021 10/05
3:16P
INTL NTWK
1
.99
.35
0022 10/05
3:17P
INTL NTWK
1
.99
.35
0023 10/05
3:17P
INTL NTWK
1
.99
.35
0024 10/05 3:43P
INTL NTWK
1
.99
.35
0025 10/05 3:45P
INTL NTWK
1
.99
.35
0026 10/05 7:48P
INTL NTWK
1
.99
.35
0027 10/05 10:03P
INTL NTWK
1
.99
.35
0028 10/06 12:00A
CALL SVC
1
.99
0029 10/06 11:20P
INTL NTWK
1
.99
.35
0030 10/06 11:20P
INTL NTWK
1
.99
.35
0031 10/07 6:24P
INTL NTWK
1
.99
.35
0032 10/08 1:02A
INTL NTWK
1
.99
.35
Subtotal for : GREAT BRITAIN,
48
47.52
15.40
.00
TOTAL ROAMING CHARGES
48
47.52
15.40
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014792

=== Page 27 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE 31.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
9/13/03 Through 10/12/03
MONTHLY SE - LOCAL PLAN $39.99
39.99
CALL FORWARDING
.00
THREE WAY CALLING
.00
CALL WAITING
.00
CALLER ID
.00
ENH DISCOUNT INTL DIAL
3.99
PCS VOICEMAIL W/NUMERIC
.00
DETAIL BILLING
.00
AT&T 2-WAY TEXT MSG $0.00
.00
AT&T TOLL FREE NATIONWIDE
4.99
AT&T TOLL FREE CREDIT
4.99CR
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
45.73
HOME AIRTIME CHARGES
9/13/03 Through 10/12/03 - LOCAL PLAN $39.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
462
.000
.00
300 ADDITIONAL MINUTES
300
.000
.00
INCLUDED IN PLAN
104
.000
.00
866
.00
TOTAL HOME AIRTIME CHARGES
.00
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
1.51
STATE TAX
2.09
LOCAL TAX
2.16
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
.94
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
1.00
GROSS RECEIPTS SURCHARGE
1.61
TOTAL TAXES, SURCHARGES & REGULATORY FEES
10.81
TOTAL CURRENT MONTHLY CHARGES
56.54
EFTA00014793

=== Page 28 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 32.0
JEFFREY E EPSTEIN &
OCT 14, 2003
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001 9/13 11:19A
INCOMING
1
0002
9/13
1:41P
INCOMING
1
0003
9/13
2:58P
NEW YORK
NY
1
0004
9/13
3:01P
INCOMING
1
0005
9/13
3:12P
NEW YORK
NY
1
0006
9/13
3:15P
BROOKLYN
NY
10
0007
9/13
4:50P
INCOMING
2
0008
9/13
5:07P
INCOMING
1
0009
9/13
5:12P
NEW YORK
NY
1
0010
9/13
5:13P
NEW YORK
NY
1
0011
9/13
5:14P
NEW YORK
NY
1
0012
9/13
8:17P
INCOMING
1
0013
9/14
12:18P
BROOKLYN
NY
1
0014
9/14
3:30P
INCOMING
1
0015
9/14
4:44P
NEW YORK
NY
1
0016
9/14
8:06P
BROOKLYN
NY
1
0017
9/14
8:07P
INCOMING
3
0018
9/15
10:25A
INCOMING
1
0019
9/15
10:40A
NEW YORK
NY
1
0020
9/15
10:44A
INCOMING
0021
9/15
11:41A
INCOMING
1
0022
9/15
11:41A
NEW YORK
NY
2
0023
9/15
11:50A
INCOMING
1
0024
9/15
12:28P
INCOMING
0025
9/15
12:30P
NEW YORK
NY
3
0026
9/15
1:37P
INCOMING
1
0027
9/15
2:01P
NEW YORK
NY
1
0028
9/15
2:07P
NEW YORK
NY
4
0029
9/15
2:28P
NEW YORK
NY
2
0030
9/15
2:47P
INCOMING
1
0031
9/15
2:49P
NEW YORK
NY
2
0032
9/15
3:00P
NEW YORK
NY
1
0033
9/15
3:01P
INCOMING
1
0034
9/15
3:13P
BROOKLYN
NY
1
0035
9/15
3:49P
INCOMING
1
0036
9/15
4:06P
NEW YORK
NY
2
0037
9/15
4:18P
NEW YORK
NY
1
0038
9/15
4:41P
INCOMING
1
0039
9/15
5:04P
INCOMING
1
0040
9/15
6:54P
NEW YORK
NY
2
0041
9/15
7:31P
INCOMING
1
0042
9/15
7:36P
INCOMING
1
0043
9/15
7:37P
NEW YORK
NY
1
0044
9/15
7:47P
INCOMING
1
0045
9/15
8:16P
NEW YORK
NY
0046
9/15
8:17P
NEW YORK
NY
2
0047
9/15
8:31P
NEW YORK
NY
1
0048
9/15
8:37P
INCOMING
1
0049
9/15
9:38P
NEW YORK
NY
2
0050
9/15
9:46P
LOCAL
1
0051
9/15
NEW YORK
NY
0052
9/15
11:25A 10:46P 10:43P
NEW YORK
NY
1
0053
9/15
10:47P
NEW YORK
NY
1
0054
9/16
9:08A
INCOMING
0055
9/16
WESTBURY
NY
2
0056
9/16
WESTBURY
NY
2
0057
9/16
1:12P
INCOMING
0058
9/16
1:44P
INCOMING
0059
9/16
1:46P
NEW YORK
NY
1
0060
9/16
1:47P
INCOMING
1
EFTA00014794

=== Page 29 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 33.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0061
9/16
1:48P
NEW YORK
NY
1
0062
9/16
1:49P
NEW YORK
NY
1
0063
9/16
3:13P
NEW YORK
NY
1
0064
9/16
3:31P
INCOMING
1
0065
9/16
3:34P
NEW YORK
NY
1
0066
9/16
3:47P
INCOMING
1
0067
9/16
3:51P
NEW YORK
NY
1
0068
9/16
4:11P
BROOKLYN
NY
5
0069
9/16
5:41P
NEW YORK
NY
2
0070
9/16
5:43P
BROOKLYN
NY
1
0071
9/16
5:44P
NEW YORK
NY
3
0072
9/16
6:55P
NEW YORK
NY
0073
9/16
6:58P
INCOMING
3
0074
9/16
7:12P
INCOMING
1
0075
9/16
7:40P
NEW YORK
NY
1
0076
9/16
7:55P
NEW YORK
NY
1
0077
9/16
7:57P
INCOMING
1
0078
9/16
8:08P
INCOMING
1
0079
9/16
8:12P
NEW YORK
NY
2
0080
9/16
8:16P
NEW YORK
NY
1
0081
9/16
8:42P
NEW YORK
NY
2
0082
9/16
9:12P
NEW YORK
NY
1
0083
9/16
9:29P
INCOMING
2
0084
9/16 10:09P
INCOMING
1
0085
9/16
10:10P
INCOMING
1
0086
9/16 11:27P
INCOMING
1
0087
9/17
8:34A
NEW YORK
NY
4
0088
9/17
9:02A
BROOKLYN
NY
17
0089
9/17
9:45A
INCOMING
1
0090
9/17
10:43A
NEW YORK
NY
0091
9/17
10:44A
INCOMING
2
0092
9/17
10:47A
NEW YORK
NY
2
0093
9/17
10:54A
INCOMING
1
0094
9/17
10:59A
INCOMING
1
0095
9/17
11:03A
NEW YORK
NY
1
0096
9/17
3:33P
NEW YORK
NY
1
0097
9/17
3:41P
INCOMING
1
0098
9/17
4:02P
NEW YORK
NY
4
0099
9/17
4:32P
INCOMING
1
0100
9/17
4:42P
INCOMING
1
0101
9/17
4:47P
INCOMING
1
0102
9/17
5:17P
NEW YORK
NY
1
0103
9/17
5:28P
INCOMING
1
0104
9/17
5:34P
INCOMING
4
0105
9/17
6:21P
INCOMING
1
0106
9/17
6:22P
INCOMING
0107
9/17
6:26P
NEW YORK
NY
1
0108
9/17
6:40P
NEW YORK
NY
1
0109
9/17
6:44P
NEW YORK
NY
0110
9/17
6:45P
INCOMING
1
0111
9/17
8:55P
INCOMING
1
0112
9/17
9:43P
NEW YORK
NY
1
0113
9/17
9:44P
NEW YORK
NY
1
0114
9/17
9:44P
NEW YORK
NY
1
0115
9/17
9:46P
NEW YORK
NY
2
0116
9/17
9:48P
NEW YORK
NY
1
0117
9/17
9:51P
NEW YORK
NY
1
0118
9/17
9:52P
INCOMING
4
0119
9/17 10:04P
INCOMING
4
0120
9/17 10:44P
INCOMING
9
EFTA00014795

=== Page 30 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 34.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0121
9/17 10:53P
NEW YORK
NY
3
0122
9/17
10:58P
BROOKLYN
NY
3
0123
9/17
11:11P
NEW YORK
NY
1
0124
9/17
11:12P
INCOMING
10
0125
9/18
12:50A
INCOMING
1
0126
9/18
8:18A
BROOKLYN
NY
2
0127
9/18
8:19A
INCOMING
1
0128
9/18
8:21A
INCOMING
1
0129
9/18
8:23A
INCOMING
2
0130
9/18
8:26A
NEW YORK
NY
1
0131
9/18
8:28A
INCOMING
1
0132
9/18
8:31A
NEW YORK
NY
0133
9/18
8:31A
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1
0134
9/18
8:33A
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1
0135
9/18
8:36A
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1
0136
9/18
8:44A
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1
0137
9/18
8:50A
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1
0138
9/18
9:06A
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1
0139
9/18
9:50A
NEW YORK
NY
1
0140
9/18
10:45A
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1
0141
9/18
10:59A
NEW YORK
NY
2
0142
9/18
1:36P
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0143
9/18
7:42P
NEW YORK
NY
0144
9/18
7:44P
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2
0145
9/18
8:06P
NEW YORK
NY
1
0146
9/18
8:07P
NEW YORK
NY
1
0147
9/18
8:08P
NEW YORK
NY
1
0148
9/18
8:40P
INCOMING
1
0149
9/18
9:18P
NEW YORK
NY
9
0150
9/18
9:26P
INCOMING
0151
9/18
9:29P
NEW YORK
NY
2
0152
9/18
9:35P
NEW YORK
NY
2
0153
9/18
9:51P
INCOMING
13
0154
9/18
10:23P
NEW YORK
NY
1
0155
9/18
10:24P
NEW YORK
NY
16
0156
9/18
11:32P
INCOMING
1
0157
9/18
11:34P
INCOMING
22
0158
9/19
12:02A
INCOMING
14
0159
9/19
12:33A
INCOMING
2
0160
9/19
1:33P
INCOMING
1
0161
9/19
4:22P
NEW YORK
NY
1
0162
9/19
5:27P
NEW YORK
NY
1
0163
9/19
5:29P
NEW YORK
NY
1
0164
9/19
6:40P
INCOMING
1
0165
9/19
9:06P
NEW YORK
NY
1
0166
9/19
11:24P
INCOMING
1
0167
9/19
11:24P
INCOMING
1
0168
9/19
11:26P
NEW YORK
NY
0169
9/19
11:28P
INCOMING
0170
9/20
2:06P
NEW YORK
NY
1
0171
9/20
2:08P
NEW YORK
NY
1
0172
9/20
2:09P
NEW YORK
NY
1
0173
9/20
2:10P
INCOMING
0174
9/20
:11P
NEW YORK
NY
1
0175
9/20
2:12P
NEW YORK
NY
1
0176
9/20
INCOMING
0177
9/20
15P
LOCAL
3
0178
9/20
6:40P
NEW YORK
NY
2
0179
9/20
6:48P
INCOMING
0180
9/20
6:56P
INCOMING
1
EFTA00014796

=== Page 31 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 35.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0181
9/20
8:06P
NEW YORK
NY
12
0182
9/20
8:41P
LOCAL
1
0183
9/20
8:42P
NEW YORK
NY
1
0184
9/20
8:43P
NEW YORK
NY
2
0185
9/20
8:55P
NEW YORK
NY
2
0186
9/20
9:29P
INCOMING
0187
9/20
9:40P
INCOMING
1
0188
20
10:01P
NEW YORK
NY
3
0189
9/20
NEW YORK
NY
1
0190
9/20
INCOMING
1
0191
9/20
INCOMING
2
0192
9/20
INCOMING
2
0193
9/20
INCOMING
1
0194
9/20
NEW YORK
NY
1
0195
9/20
INCOMING
0196
20
INCOMING
0197
9/20
NEW YORK
NY
0198
2:42P
NEW YORK
NY
8
0199
INCOMING
1
0200
3:57P
NEW YORK
NY
3
0201
NEW YORK
NY
0202
INCOMING
0203
INCOMING
1
0204
7:10P
NEW YORK
NY
1
0205
NEW YORK
NY
1
0206
7:30P
NEW YORK
NY
2
0207
7:48P
NEW YORK
NY
1
0208
NEW YORK
NY
1
0209
NEW YORK
NY
1
0210
NEW YORK
NY
0211
INCOMING
1
0212
NEW YORK
NY
2
0213
INCOMING
1
0214
22
NEW YORK
NY
1
0215
2:08P
INCOMING
1
0216
2:35P
NEW YORK
NY
1
0217
2:42P
INCOMING
1
0218
1
INCOMING
1
0219
INCOMING
12
0220
:02A
NEW YORK
NY
9
0221
23
INCOMING
2
0222
23
INCOMING
9
0223
7:53P
NEW YORK
NY
1
0224
9/23
INCOMING
1
0225
23
9:16P
NEW YORK
NY
3
0226
23
NEW YORK
NY
13
0227
23
INCOMING
4
0228
23
10:13P
NEW YORK
NY
1
0229
23
INCOMING
4
0230
9/24
INCOMING
1
0231
24
INCOMING
1
0232
24
3:50P
NEW YORK
NY
1
0233
24
INCOMING
2
0234
9/24
P
INCOMING
1
0235
9/24
P
INCOMING
1
0236
9/24
P
NEW YORK
NY
1
0237
9/24
4:38P
INCOMING
0238
9/24
4:59P
INCOMING
0239
9/24
5:01P
INCOMING
0240
9/24
NEW YORK
NY
2
EFTA00014797

=== Page 32 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 36.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0241
9/24
5:44P
INCOMING
1
0242
9/24
6:31P
NEW YORK
NY
1
0243
9/24
6:44P
NEW YORK
NY
4
0244
9/24
6:48P
NEW YORK
NY
1
0245
9/24
7:46P
NEW YORK
NY
2
0246
9/24
7:48P
W
INCOMING
0247
9/24
9:35P
NEW YORK
NY
2
0248
9/24
10:08P
NEW YORK
NY
1
0249
9/24
10:48P
NEW YORK
NY
5
0250
9/25 12:22A
NEW YORK
NY
4
0251
9/25
1:05A
NEW YORK
NY
1
0252
9/25
11:21A
NEW YORK
NY
0253
9/25
11:41A
INCOMING
0254
9/25
12:00P
NEW YORK
NY
2
0255
9/25
12:33P
NEW YORK
NY
0256
9/26
4:00P
INCOMING
0257
9/26
4:07P
INCOMING
0258
9/26
4:14P
INCOMING
2
0259
9/26
4:37P
NEW YORK
NY
0260
9/26
4:45P
NEW YORK
NY
0261
9/26
4:55P
NEW YORK
NY
0262
9/26
5:07P
NEW YORK
NY
2
0263
9/26
5:08P
INCOMING
0264
9/26
5:12P
INCOMING
0265
9/26
5:30P
INCOMING
0266
9/26
5:37P
INCOMING
0267
9/26
5:50P
INCOMING
0268
9/26
6:09P
INCOMING
1
0269
9/26
7:02P
NEW YORK
NY
4
0270
9/27
1:46P
BROOKLYN
NY
3
0271
9/27
3:28P
LAS VEGAS
NV
14
0272
9/27
4:11P
INCOMING
1
0273
9/27
4:18P
NEW YORK
NY
1
0274
9/27
4:19P
INCOMING
1
0275
9/27
4:39P
NEW YORK
NY
2
0276
9/27
4:50P
INCOMING
1
0277
9/27
4:56P
NEW YORK
NY
1
0278
9/27
5:01P
INCOMING
1
0279
9/27
5:21P
INCOMING
2
0280
9/27
6:40P
NEW YORK
NY
1
0281
9/28
3:02P
NEW YORK
NY
0282
9/29
10:26A
NEW YORK
NY
0283
9/29
10:38A
NEW YORK
NY
0284
9/29
10:39A
NEW YORK
NY
3
0285
9/29
10:50A
INCOMING
0286
9/29
02A
NEW YORK
NY
0287
9/29
11:30A
NEW YORK
NY
0288
9/29
11:32A
INCOMING
0289
9/29
11:52A
NEW YORK
NY
2
0290
9/29
1:04P
NEW YORK
NY
0291
9/29
1:11P
NEW YORK
NY
0292
9/29
1:25P
INCOMING
0293
9/29
1:29P
NEW YORK
NY
0294
9/29
1:49P
NEW YORK
NY
0295
9/29
1:50P
NEW YORK
NY
0296
9/29
3:09P
INCOMING
2
0297
9/29
8:42P
INCOMING
0298
9/29
10:09P
LOCAL
0299
9/29
11:25P
NEW YORK
NY
14
0300
9
11:47P
NEW YORK
NY
4
EFTA00014798

=== Page 33 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 37.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0301 9/30 12:14A
NEW YORK
NY
1
0302
9/30
12:18A
NEW YORK
NY
1
0303
9/30
7:58A
INCOMING
0304
9/30
8:51A
INCOMING
0305
9/30
8:56A
INCOMING
2
0306
9/30
8:59A
INCOMING
0307
9/30
3:37P
INCOMING
2
0308
9/30
8:44P
W PALM BCH FL
0309
10/01
8:41A
INCOMING
0310
10/01
9:14A
INCOMING
0311
10/01
10:43A
BROOKLYN
NY
0312
10/01
4A
BROOKLYN
NY
0313
10/01
11:21A
BROOKLYN
NY
0314
10/01
INCOMING
0315
10/01
NEW YORK
NY
2
0316
10/01
12:35P
INCOMING
0317
10/01
:15P
NEW YORK
NY
2
0318
10/01
1:20P
NEW YORK
NY
0319
10/01
1:41P
INCOMING
0320
10/01
2:00P
NEW YORK
NY
0321
10/01
2:06P
NEW YORK
NY
0322
10/01
:17P
NEW YORK
NY
3
0323
10/01
2:26P
NEW YORK
NY
2
0324
10/01
3:32P
NEW YORK
NY
3
0325
10/02
1:19P
NEW YORK
NY
0326
10/03
6:44P
INCOMING
0327
10/03
9:11P
NEW YORK
NY
0328
10/03
10:55P
INCOMING
0329
10/03
11:15P
NEW YORK
NY
1
0330
10/03
NEW YORK
NY
0331
10/04
12:21A
NEW YORK
NY
0332
10/05
2:04P
NEW YORK
NY
0333
10/05
9:06P
LOCAL
2
0334
10/06
8:00A
INCOMING
0335
10/06
01A
NEW YORK
NY
0336
10/06
03A
LOCAL
0337
10/06
8:58A
BROOKLYN
NY
0338
10/06
9:42A
NEW YORK
NY
0339
10/06
9:55A
NEW YORK
NY
0340
10/06
0341
10/06
10:32A
BROOKLYN
NY
BROOKLYN
NY
0342
10/06
1:52P
NEW YORK
NY
2
0343
10/06
2:24P
NEW YORK
NY
0344
10/07
9:51A
INCOMING
0345
10/07
10:25A
NEW YORK
NY
3
0346
10/07
4:17P
LOCAL
0347
10/07
4:19P
BROOKLYN
NY
2
0348
10/07
4:26P
INCOMING
0349
10/07
4:39P
NEW YORK
NY
0350
10/07
4:59P
INCOMING
0351 10/07
5:02P
BROOKLYN
NY
2
0352
10/07
5:28P
BROOKLYN
NY
0353
10/07
6:01P
BROOKLYN
NY
0354
10/07
7:36P
BROOKLYN
NY
0355
10/07
7:36P
NEW YORK
NY
0356
10/08
:14P
NEW YORK
NY
0357
10/08
6
:21P
NEW YORK
NY
0358
10/08
6:34P
INCOMING
0359
10/08
7:21P
INCOMING
0360
10/08
7:40P
NEW YORK
NY
EFTA00014799

=== Page 34 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 38.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0361
10/08
8:16P
INCOMING
1
0362
10/09
10:26A
NEW YORK
NY
1
0363
10/09
10:47A
NEW YORK
NY
0364
10/09
10:52A
NEW YORK
NY
2
0365
10/09
10:53A
BROOKLYN
NY
3
0366
10/09
11:04A
NEW YORK
NY
0367
10/09
11:10A
NEW YORK
NY
3
0368
10/09
11:22A
INCOMING
0369
10/09
12:23P
NEW YORK
NY
0370
10/09
12:29P
INCOMING
0371
10/09
12:32P
NEW YORK
NY
0372
10/09
12:45P
NEW YORK
NY
2
0373
10/09
12:46P
NEW YORK
NY
0374
10/09
1:06P
NEW YORK
NY
0375
10/09
1:06P
NEW YORK
NY
0376
10/09
1:08P
INCOMING
0377
10/09
1:44P
NEW YORK
NY
0378
10/09
1:46P
INCOMING
0379
10/09
1:50P
NEW YORK
NY
2
0380
10/09
2:28P
INCOMING
2
0381
10/09
2:32P
INCOMING
0382
10/09
3:17P
INCOMING
0383
10/09
4:33P
NEW YORK
NY
0384
10/09
4:54P
NEW YORK
NY
0385
10/09
4:59P
NEW YORK
NY
0386
10/09
5:00P
NEW YORK
NY
0387
10/09
5:01P
NEW YORK
NY
0388
10/09
5:05P
NEW YORK
NY
2
0389
10/09
5:06P
INCOMING
0390
10/09
5:21P
INCOMING
0391
10/09
5:22P
NEW YORK
NY
0392
10/09
5:31P
INCOMING
0393
10/09
5:33P
INCOMING
0394
10/09
5:46P
NEW YORK
NY
0395
10/09
5:49P
BROOKLYN
NY
0396
10/09
5:51P
NEW YORK
NY
0397
10/09
5:52P
BROOKLYN
NY
0398
10/09
5:54P
BROOKLYN
NY
0399
10/09
:10P
INCOMING
2
0400
10/09
6:15P
INCOMING
0401
10/09
6:15P
INCOMING
0402
10/09
6:19P
NEW YORK
NY
0403
10/09
6:37P
INCOMING
0404
10/09
6:40P
INCOMING
0405
10/09
7:46P
INCOMING
0406
10/09
7:47P
INCOMING
0407
10/10
10:08A
NEW YORK
NY
0408
10/10
10:09A
NEW YORK
NY
2
0409
10/10
11:35A
NEW YORK
NY
0410
10/10
12:06P
INCOMING
0411
10/10
12:34P
NEW YORK
NY
0412
10/10
2:15P
BROOKLYN
NY
2
0413
10/10
4:28P
INCOMING
0414
10/10
4:51P
NEW YORK
NY
0415
10/10
5:00P
NEW YORK
NY
0416
10/10
5:03P
NEW YORK
NY
0417
10/10
5:03P
NEW YORK
NY
0418
10/10
5:44P
INCOMING
2
0419
10/10
5:50P
NEW YORK
NY
0420
10/10
6:04P
INCOMING
EFTA00014800

=== Page 35 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 39.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0421 10/10 6:12P
NEW YORK
NY
1
0422 10/10 6:57P
INCOMING
1
0423 10/10 9:39P
QUEENS
NY
1
0424 10/10 9:48P
NEW YORK
NY
1
0425 10/10 10:00P
NEW YORK
NY
1
0426 10/10 10:04P
INCOMING
1
0427 10/10 10:10P
INCOMING
2
0428 10/10 10:35P
NEW YORK
NY
1
0429 10/10 10:36P
NEW YORK
NY
1
0430 10/10 10:37P
INCOMING
8
0431 10/10 11:35P
NEW YORK
NY
1
0432 10/10 11:56P
INCOMING
1
0433 10/11 12:12A
NEW YORK
NY
27
0434 10/11 12:38A W
INCOMING
1
0435
10/11
8:48A
INCOMING
1
0436 10/11 8:58A
BROOKLYN
NY
1
0437 10/11 9:28A
INCOMING
1
0438 10/11 9:30A
NEW YORK
NY
21
0439 10/11 10:10A
INCOMING
1
0440 10/11 10:40A
INCOMING
1
0441 10/11 10:41A
BROOKLYN
NY
0442 10/11 10:43A
INCOMING
1
0443 10/11 10:47A
INCOMING
1
0444 10/11 10:52A
NEW YORK
NY
1
0445 10/11 10:53A
NEW YORK
NY
1
0446 10/11 10:56A
NEW YORK
NY
1
0447 10/11 10:59A
INCOMING
2
0448 10/11 11:00A
BROOKLYN
NY
1
0449 10/11 11:01A
NEW YORK
NY
2
0450 10/11 11:02A W
INCOMING
3
0451 10/11 11:05A
INCOMING
1
0452 10/11 11:06A
INCOMING
1
0453 10/11 11:09A
INCOMING
1
0454 10/11 12:24P
NEW YORK
NY
1
0455 10/11 12:25P
NEW YORK
NY
2
0456 10/11 12:33P
NEW YORK
NY
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
866
.00
.00
CALL CHARACTERISTICS:
W = Call Waiting
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014801

=== Page 36 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 41.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
9/13/03 Through 10/12/03
MONTHLY SE - NATIONAL PLAN $199.99
199.99
CALL FORWARDING
.00
CALL WAITING
.00
CALLER ID
.00
WORLDCONNECT
7.99
EQUIP INS PREMIUM/FEE
3.99
PCS VOICEMAIL W/NUMERIC
.00
DETAIL BILLING
.00
AT&T 2-WAY TEXT MSG $0.00
.00
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
213.72
HOME AIRTIME CHARGES
9/13/03 Through 10/12/03 - NATIONAL PLAN $199.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
690
.000
.00
200 ADDITIONAL MINUTES
200
.000
.00
INCLUDED IN PLAN
1140
.000
.00
2030
.00
TOTAL HOME AIRTIME CHARGES
.00
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
38.30
TOTAL HOME LONG DISTANCE CHARGES
38.30
MESSAGING, CONTENT & APPLICATION CHARGES
9/13/03 Through 10/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
19
.10
1.90
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
1.90
EFTA00014802

=== Page 37 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE NUMBER BILL DATE PAGE 42.0
JEFFREY E EPSTEIN &
OCT 14, 2003
SUMMARY OF CHARGES (CONTINUED)
ROAMING CHARGES
ROAMING AIR
108.33
ROAMING LONG DISTANCE CHARGES
5.60
TOTAL ROAMING CHARGES
113.93
OTHER CHARGES AND CREDITS
AT&T CONNECT CALLS
9 CALLS
11.25
TOTAL OTHER CHARGES AND CREDITS
11.25
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
12.10
STATE TAX
15.67
LOCAL TAX
16.13
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
7.67
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
8.20
GROSS RECEIPTS SURCHARGE
13.34
TOTAL TAXES, SURCHARGES & REGULATORY FEES
74.61
TOTAL CURRENT MONTHLY CHARGES
453.71
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0001 9/13 10:57A
LOCAL
4
0002 9/13 11:00A
NEW YORK
NY
5
0003 9/13 11:05A
NEW YORK
NY
3
0004 9/13 11:06A
INCOMING
1
0005
9/13
11:08A
D
QUEENS
NY
3
0006 9/13 11:09A
INCOMING
6
0007 9/13 11:11A D
DIR ASST
2
0008 9/13 11:15A
NEW YORK
NY
2
0009 9/13 11:18A
FRANCE
2
.700
0010 9/13 11:53A
INCOMING
2
0011 9/13 12:03P
INCOMING
6
0012 9/13 12:41P
NEW YORK
NY
1
0013 9/13 12:52P
INCOMING
PPPPHONNNNGWPWL
1
0014 9/13 12:53P
NEW YORK
NY
1
0015 9/13 12:56P
INCOMING
1
0016
9/13
12:56P
NEW YORK
NY
1
0017
9/13
1:15P
INCOMING
2
0018
9/13
2:45P
INCOMING
4
0019 9/13 3:04P
INCOMING
3
EFTA00014803

=== Page 38 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 43.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0020
9/13
4:31P
INCOMING
3
0021
9/13
5:07P
INCOMING
5
0022
9/13
5:14P
W PALM BCH FL
2
0023
9/13
5:15P
FRANCE
2
.700
0024
9/13
5:48P
INCOMING
5
0025
9/13
6:30P
LOCAL
1
0026
9/13
6:52P
INCOMING
1
0027
9/13
6:53P
NEW YORK
NY
1
0028
9/13
7:25P
INCOMING
1
0029
9/13
9:48P
NWYRCYZN01 NY
6
0030
9/14
11:43A
D
DIR ASST
1
0031
9/14
1:21P
INCOMING
6
0032
9/14
2:38P
INCOMING
1
0033
9/14
3:49P
NEW YORK
NY
1
0034
9/14
3:59P
INCOMING
7
0035
9/14
4:20P
INCOMING
2
0036
9/14
4:26P
NEW YORK
NY
1
0037
9/14
5:49P
INCOMING
1
0038
9/14
5:50P
NEW YORK
NY
1
0039
9/15
9:08A
NEW YORK
NY
1
0040
9/15
9:11A
NEW YORK
NY
1
0041
9/15
9:12A
NEW YORK
NY
1
0042
9/15
9:14A
NEW YORK
NY
1
0043
9/15
9:14A
NWYRCYZN01
NY
1
0044
9/15
9:17A
LOCAL
2
0045
9/15
9:19A
NEW YORK
NY
11
0046
9/15
9:31A
FRANCE
2
.700
.
0047
9/15
9:33A
NEW YORK
NY
3
0048
9/15
9:41A
INCOMING
1
0049
9/15
9:45A
NEW YORK
NY
1
0050
9/15
9:49A
INCOMING
2
0051
9/15
10:15A
INCOMING
2
0052
9/15
10:40A
NEW ALBANY
OH
2
0053
9/15
10:41A
MOBILE
NY
2
0054
9/15
10:45A
NEW YORK
NY
2
0055
9/15
10:53A
INCOMING
1
0056
9/15
11:08A
NEW YORK
NY
2
0057
9/15
11:59A
INCOMING
1
0058
9/15
12:14P
NEW YORK
NY
8
0059
9/15
12:22P
INCOMING
1
0060
9/15
1:14P
NWYRCYZN01 NY
1
0061
9/15
1:39P
INCOMING
1
0062
9/15
1:58P
INCOMING
1
0063
9/15
3:58P
INCOMING
1
0064
9/15
4:03P
INCOMING
4
0065
9/15
4:26P
INCOMING
2
0066
9/15
4:36P
INCOMING
1
0067
9/15
4:43P
INCOMING
2
0068
9/15
4:47P
OAHU
HI
2
0069
9/15
4:48P
NWYRCYZN01
NY
2
0070
9/15
4:51P
NEW YORK
NY
1
0071
9/15
4:51P
NEW YORK
NY
1
0072
9/15
4:52P
INCOMING
5
0073
9/15
5:34P
LOCAL
1
0074
9/15
5:35P
INCOMING
1
0075
9/15
5:36P
LOCAL
1
0076
9/15
5:37P
NEW YORK
NY
12
0077
9/15
5:49P
INCOMING
4
0078
9/15
:12P
LOCAL
1
0079
9/15
7:36P
LOCAL
3
EFTA00014804

=== Page 39 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 44.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0080
9/15
7:45P
MOBILE
NY
1
0081
9/15
7:58P
INCOMING
22
0082
9/15
8:23P
LOCAL
1
0083
9/15
8:42P
NEW YORK
NY
2
0084
9/15
INCOMING
6
0085
9/15
9:06P
INCOMING
1
0086
9/16
8:34A
NEW YORK
NY
8
0087
9/16
9:01A
NEW YORK
NY
1
0088
9/16
01A
NEW YORK
NY
1
0089
9/16
9:02A
INCOMING
1
0090
9/16
9:02A
LOCAL
1
0091
9/16
9:43A
INCOMING
2
0092
9/16
INCOMING
4
0093
9/16
12:32P
MOBILE
NY
1
0094
9/16
1
NEW YORK
NY
5
0095
9/16
1
INCOMING
1
0096
9/16
:12P
NEW YORK
NY
0097
9/16
NEW YORK
NY
3
0098
9/16
26P
INCOMING
1
0099
9/16
INCOMING
4
0100
9/16
:36P
NEW YORK
NY
0101
9/16
1:50P
NEW YORK
NY
2
0102
9/16
:12P
NEW YORK
NY
0103
9/16
37P
INCOMING
0104
9/16
:54P
INCOMING
0105
9/16
:59P
INCOMING
0106
9/16
2:59P
INCOMING
2
0107
9/16
:15P
LOCAL
2
0108
9/16
4:16P
LAS VEGAS
NV
0109
9/16
4:40P
LAS VEGAS
NV
9
0110
9/16
5:39P
INCOMING
3
0111
9/16
5:41P
NEW YORK
NY
1
0112
9/16
5:47P
INCOMING
3
0113
9/16
6:46P
INCOMING
1
0114
9/16
9:08P
LOCAL
1
0115
9/16
9:08P
LOCAL
1
0116
9/16
9:09P
NEW YORK
NY
8
0117
9/16
10:03P
NEW YORK
NY
2
0118
9/17
8:23A
NEW YORK
NY
4
0119
9/17
8:29A
NEW YORK
NY
1
0120
9/17
8:33A
NEW YORK
NY
2
0121
9/17
8:35A
800 SERV.
2
0122
9/17
9A
NEW YORK
NY
0123
9/17
3A
NEW YORK
NY
0124
9/17
3A
NEW YORK
NY
0125
9/17
4A
NEW YORK
NY
0126
9/17
6A
NEW YORK
NY
1
0127
9/17
8A
INCOMING
0128
9/17
1A
NEW YORK
NY
0129
9/17
9:56A
INCOMING
0130
9/17
10:23A
INCOMING
1
0131
9/17
12:41P
NEW YORK
NY
0132
9/17
12:42P
NEW YORK
NY
3
0133
9/17
12:44P
MOBILE
NY
1
0134
9/17
12:50P
INCOMING
4
0135
9/17
1:40P
W PALM BCH FL
2
0136
9/17
1:46P
INCOMING
1
0137
9/17
2:28P
INCOMING
1
0138
9/17
2:32P
INCOMING
0139
9/17
2:32P
W PALM BCH FL
1
EFTA00014805

=== Page 40 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER
BILL DATE PAGE 45.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0140
9/17
2:33P
W PALM BCH FL
2
0141
9/17
2:49P
INCOMING
5
0142
9/17
2:54P
MOBILE
NY
2
0143
9/17
3:04P
MOBILE
NY
1
0144
9/17
3:07P
NEW YORK
NY
6
0145
9/17
3:26P
INCOMING
9
0146
9/17
3:58P
MOBILE
NY
1
0147
9/17
4:22P
INCOMING
1
0148
9/17
4:25P
LAS VEGAS
NV
2
0149
9/17
4:28P
NEW YORK
NY
1
0150
9/17
4:29P
NEW YORK
NY
1
0151
9/17
4:30P
NEW YORK
NY
0152
9/17
4:32P
NEW YORK
NY
1
0153
9/17
4:37P
LOCAL
1
0154
9/17
4:37P
NEW YORK
NY
1
0155
9/17
4:39P
NEW YORK
NY
1
0156
9/17
4:41P
NEW YORK
NY
1
0157
9/17
4:42P
NEW YORK
NY
2
0158
9/17
4:47P
NEW YORK
NY
1
0159
9/17
4:49P
MOBILE
NY
1
0160
9/17
4:54P
NEW YORK
NY
0161
9/17
4:55P
INCOMING
6
0162
9/17
5:28P
NEW YORK
NY
1
0163
9/17
5:46P
QUEENS
NY
3
0164
9/17
5:49P
INCOMING
1
0165
9/17
5:51P
INCOMING
2
0166
9/17
5:52P
NEW YORK
NY
1
0167
9/17
5:53P
LOCAL
1
0168
9/17
5:55P
LOCAL
1
0169
9/17
5:56P
MOBILE
NY
24
0170
9/17
6:21P
NEW YORK
NY
1
0171
9/17
6:22P
NEW YORK
NY
1
0172
9/17
6:31P
INCOMING
7
0173
9/17
6:37P
LOCAL
2
0174
9/17
7:36P
NEW YORK
NY
1
0175
9/17
7:38P
INCOMING
1
0176
9/17
7:39P
W PALM BCH
FL
1
0177
9/17
7:40P
MOBILE
NY
1
0178
9/17
7:42P
MOBILE
NY
1
0179
9/17
7:43P
NEW YORK
NY
5
0180
9/17
7:49P
NEW YORK
NY
1
0181
9/17
7:50P
MOBILE
NY
1
0182
9/17
7:52P
MOBILE
NY
2
0183
9/17
7:53P
MOBILE
NY
4
0184
9/17
8:07P
INCOMING
10
0185
9/17
8:14P
INCOMING
7
0186
9/17
8:21P
MOBILE
NY
4
0187
9/17
8:25P
MOBILE
NY
2
0188
9/17
8:27P
NEW YORK
NY
2
0189
9/17
8:28P
LOCAL
3
0190
9/17
8:32P
D
DIR ASST
2
0191
9/17
8:34P
MOBILE
NY
2
0192
9/17
8:36P
NEW YORK
NY
2
0193
9/17
8:37P
MOBILE
NY
2
0194
9/17
8:42P
INCOMING
2
0195
9/17
8:44P
LOCAL
1
0196
9/17
8:54P
NEW YORK
NY
0197
9/17
8:55P
INCOMING
0198
9/17
8:56P
NEW YORK
NY
0199
9/17
8:57P
LOCAL
1
EFTA00014806

=== Page 41 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 46.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0200
9/17
8:58P
NEW YORK
NY
3
0201
9/17
9:13P
NEW YORK
NY
2
0202
9/17
9:19P
INCOMING
3
0203
9/17
9:21P
NEW YORK
NY
2
0204
9/17
9:23P
NEW YORK
NY
1
0205
9/17
9:32P
INCOMING
0206
9/17
10:47P
INCOMING
1
0207
9/18
12:20A
NEW YORK
NY
4
0208
9/18
12:30A
UN. KINGDO
1
.350
0209
9/18
1:30A
UN. KINGDO
1
.350
0210
9/18
8:19A
NEW YORK
NY
1
0211
9/18
8:19A
INCOMING
2
0212
9/18
8:20A
NEW YORK
NY
1
0213
9/18
8:21A
NEW YORK
NY
1
0214
9/18
8:22A
NEW YORK
NY
2
0215
9/18
8:25A
QUEENS
NY
0216
9/18
8:26A
INCOMING
0217
9/18
8:26A
NEW YORK
NY
0218
9/18
8:27A
NEW YORK
NY
0219
9/18
8:31A
NEW YORK
NY
0220
9/18
8:32A
LOCAL
0221
9/18
8:32A
NEW YORK
NY
0222
9/18
8:36A
NEW YORK
NY
0223
9/18
8:39A
NEW YORK
NY
0224
9/18
8:39A
NEW YORK
NY
0225
9/18
8:43A
NEW YORK
NY
0226
9/18
8:44A
LOCAL
0227
9/18
8:44A
NEW YORK
NY
2
0228
9/18
8:46A
NEW YORK
NY
3
0229
9/18
8:49A
NEW YORK
NY
2
0230
9/18
8:51A
NEW YORK
NY
5
0231
9/18
8:56A
MOBILE
NY
0232
9/18
8:57A
MOBILE
NY
0233
9/18
9:00A
MOBILE
NY
1
0234
9/18
9:00A
MOBILE
NY
1
0235
9/18
9:02A
MOBILE
NY
1
0236
9/18
9:05A
NEW YORK
NY
1
0237
9/18
9:06A
MOBILE
NY
0238
9/18
9:07A
MOBILE
NY
1
0239
9/18
9:08A
MOBILE
NY
1
0240
9/18
9:11A
INCOMING
1
0241
9/18
9:12A
NEW YORK
NY
1
0242
9/18
9:12A
NEW YORK
NY
0243
9/18
9:14A
NEW YORK
NY
2
0244
9/18
9:15A
INCOMING
1
0245
9/18
9:16A
NEW YORK
NY
1
0246
9/18
9:17A
LOCAL
0247
9/18
9:17A
NEW YORK
NY
6
0248
9/18
9:24A
NEW YORK
NY
7
0249
9/18
9:49A
INCOMING
1
0250
9/18
10:16A
INCOMING
1
0251
9/18
10:39A
NEW YORK
NY
7
0252
9/18
11:18A
NEW YORK
NY
2
0253
9/18
11:23A
INCOMING
0254
9/18
MOBILE
NY
0255
9/18
11:34A
QUEENS
NY
2
0256
9/18
NEW YORK
NY
3
0257
18
LOCAL
0258
9
1:17P
INCOMING
0259
9/18
1:36P
INCOMING
1
EFTA00014807

=== Page 42 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 47.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0260
9/18
1:43P
INCOMING
1
0261
9/18
1:44P
LOCAL
1
0262
9/18
1:45P
INCOMING
1
0263
9/18
1:56P
INCOMING
0264
9/18
2:08P
INCOMING
1
0265
9/18
:10P
INCOMING
1
0266
9/18
:19P
INCOMING
1
0267
9/18
:21P
W PALM BCH FL
2
0268
9/18
:22P
NEW YORK
NY
1
0269
9/18
2:23P
LOCAL
1
0270
9/18
2:25P
W PALM BCH FL
1
0271
9/18
2:36P
NEW YORK
NY
1
0272
9/18
2:43P
INCOMING
1
0273
9/18
NEW YORK
NY
4
0274
9/18
2:48P
W PALM BCH FL
2
0275
9/18
2:50P
LOCAL
0276
9/18
2:50P
NEW YORK
NY
2
0277
9/18
NEW YORK
NY
5
0278
9/18
NWYRCYZN01 NY
2
0279
9/18
3:03P
LAS VEGAS
NV
2
0280
9/18
:04P
LAS VEGAS NV
1
0281
9/18
:15P
INCOMING
1
0282
9/18
:15P
W PALM BCH FL
1
0283
9/18
:27P
INCOMING
1
0284
9/18
:28P
W PALM BCH FL
1
0285
9/18
W PALM BCH FL
1
0286
9/18
3:29P
W PALM BCH FL
1
0287
9/18
3:45P
NEW YORK
NY
2
0288
9/18
3:46P
LOCAL
1
0289
9/18
3:47P
UN. KINGDO
16
5.600
0290
9/18
4:03P
W PALM BCH FL
1
0291
9/18
4:08P
W PALM BCH FL
1
0292
9/18
4:09P
W PALM BCH FL
2
0293
9/18
4:21P
NEW YORK
NY
1
0294
9/18
4:32P
OAHU
HI
1
0295
9/18
4:33P
MOBILE
NY
2
0296
9/18
4:52P
W PALM BCH
FL
1
0297
9/18
4:58P
NEW YORK
NY
4
0298
9/18
8:25P
NEW YORK
NY
WP
1
0299
9/18
9:13P
NEW YORK
NY
WP
1
0300
9/19
8:48A
NEW YORK
NY
WP
1
0301
9/19
11:11A
NEW YORK
NY
WP
2
0302
9/19
11:45A
NEW YORK
NY
WP
2
0303
9/19
12:57P
NEW YORK
NY WP
1
0304
9/19
1:07P
LDW PALM BCH FL
NY
0305
9/19
1:08P
INCOMING
WP
1
0306
9/19
1:27P
LDW PALM BCH FL
NY
0307
9/19
1:29P
INCOMING
WP
1
0308
9/19
1:39P
LDW PALM BCH FL NY
0309
9/19
1:40P
INCOMING
WP
7
0310
9/19
1:52P
LDW PALM BCH FL
NY
0311
9/19
1:54P
INCOMING
WP
3
0312
9/19
2:12P
W PALM BCH FL WP
1
0313
9/19
:12P
NEW YORK
NY
WP
1
0314
9/19
:18P
W PALM BCH FL WP
1
0315
9/19
2:45P
NEW ALBANY OH
WP
1
0316
9/19
2:46P
NEW ALBANY OH
WP
1
0317
9/19
2:49P
W PALM BCH FL WP
2
0318
9/19
2:51P
NEW YORK NY WP
1
0319
9/19
2:51P
NEW YORK
NY
WP
1
EFTA00014808

=== Page 43 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE NUMBER BILL DATE PAGE 48.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0320
9/19
2:52P
W PALM BCH FL WP
0321
9/19
2:53P
NEW YORK
NY
WP
0322
9/19
UN. KINGDO
W
3.150
0323
9/19
:03P
W PALM BCH FL
W
0324
9/19
:04P
W PALM BCH FL
W
0325
9/19
:13P
W PALM BCH FL
W
0326
19
19P
W PALM BCH FL
W
0327
19
:20P
NEW YORK
NY
W
0328
19
:28P
WEST PALM
FL
W
0329
19
:30P
LDW PALM BCH
FL
NY
0330
19
QUEENS
NY
W
0331
19
INCOMING
WP
0332
19
33P
BROOKLYN
NY
WP
0333
19
LDW PALM BCH FL
NY
0334
9/19
INCOMING
WP
0335
9/19
4:22P
WEST PALM
FL
WP
0336
9/19
WEST PALM
FL
WP
0337
9/19
5:49P
LDW PALM BCH FL
NY
0338
9/19
5:50P
INCOMING
WP
0339
9/19
5:57P
LDW PALM BCH FL
NY
0340
9/19
5:58P
INCOMING
WP
0341
9/19
6:38P
LDW PALM BCH FL
NY
0342
9/19
INCOMING
WP
0343
9/19
7:00P
NEW YORK
NY
W
0344
9/19
9:37P
NEW YORK
NY
W
0345
9/19
9:52P
BROOKLYN
NY
WP
0346
9/19
10:00P
LDW PALM BCH FL
NY
0347
9/19
10:01P
INCOMING
WP
0348
9/20
1:02P
LDW PALM BCH FL
NY
0349
9/20
1:03P
INCOMING
W
0350
9/20
LDW PALM BCH FL
NY
0351
9/20
1:23P
INCOMING
WP
0352
9/20
1:33P
LDW PALM BCH FL
NY
0353
9/20
1:34P
INCOMING
WP
0354
9/20
2:02P
NEW YORK
NY
W
0355
9/20
2:20P
CHARLT AML
VI
W
.400
0356
9/20
2:30P
NEW YORK
NY
W
0357
9/20
2:37P
NEW YORK
NY
W
0358
9/20
2:38P
WEST PALM
FL
W
0359
9/20
3:14P
NEW YORK
NY
W
0360
9/20
:20P
LDW PALM BCH
FL
NY
0361
9/20
:22P
INCOMING
WP
0362
9/20
:22P
WEST PALM
FL
WP
0363
9/20
:24P
OAHU
HI
WP
0364
9/20
:39P
LDW PALM BCH
FL
NY
0365
9/20
3:40P
INCOMING
WP
0366
9/20
3:58P
LDW PALM BCH FL
NY
41 15 NHH 2-13 251 2 3 2 NAMELY HHH 7 5 1 1 1 1 1 1 1 1 9 9 1 1 1 3
0367
9/20
3:59P
W
INCOMING
WP
0368
9/20
LAS VEGAS
NV
WP
0369
9/20
WEST PALM
FL
WP
0370
9/20
:59P
LDW PALM BCH FL
NY
0371
9/20
5:00P
INCOMING
W
0372
9/20
8:28P
NEW YORK
NY
W
0373
9/20
8:29P
UN. KINGDO
WP
.700
0374
9/20
9:14P
NEW YORK
NY
WP
0375
9/20
9:40P
UN. KINGDO
WP
.350
0376
9
8:58A
NEW YORK
NY
W
P
0377
9/21
10:09A
LDW PALM BCH FL
NY
0378
9/21 10:11A
INCOMING
WP
0379
9/21
10:43A
LDW PALM BCH FL NY
EFTA00014809

=== Page 44 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 49.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0380 9/21 10:44A
INCOMING
WP
0381
9/21
12:46P
LDW PALM BCH FL
NY
0382
9/21
12:47P
INCOMING
WP
0383
9/21
1:02P
LDW PALM BCH FL
NY
0384
9/21
1:03P
INCOMING
WP
0385
9/21
:04P
1
WEST PALM
FL
WP
0386
9/21
1:06P
NEW YORK
NY
WP
0387
9/21
1:29P
NEW YORK
NY
WP
0388
9/21
1:32P
QUEENS
NY
WP
0389
9/21
1:35P
WEST PALM
FL
WP
0390
9/21
1:54P
LDW PALM BCH
FL
NY
0391
9/21
1:55P
INCOMING
WP
0392
9/21
1:55P
5 QUEENS
NY
WP
0393
9/21
2:13P
LDW PALM BCH FL
NY
0394
9/21
:14P
INCOMING
WP
0395
9/21
2:41P
LDW PALM BCH FL NY
0396
9/21
2:42P
INCOMING
WP
0397
9/21
4:17P
NEW YORK
NY
WP
1 2 2 2 2 5 2 3 1 1 3 1 3 1 1
0398
9/21
6:18P
in
QUEENS
NY
WP
0399
9/21
10:47P
LDW PALM BCH FL NY
0400
9/21
10:49P
INCOMING
WP
0401
9/21
11:33P
LDW PALM BCH FL NY
0402
9/21
11:33P
INCOMING
WP
0403
9/22
12:15P
LDSANTURCE
PR
NY
.200
0404
9/22
5:04P
LDSANTURCE
PR NY
.200
0405
9/22
6:28P
LDSANTURCE
PR NY
.800
0406
9/23
2:45P
LDSANTURCE
PR
NY
.400
0407
9/24
1
58P
LDSANTURCE
PR
NY
1.000
0408
9/24
:51P
LDSANTURCE
PR
NY
.800
0409
9/24
3:09P
LDSANTURCE
PR
NY
.200
0410
9/25
12:50P
LDSANTURCE
PR
NY
2.200
0411
9/25
1:06P
LDSANTURCE
PR NY
.200
0412
9/25
:24P
LDSANTURCE
PR
NY
.200
0413
9/25
:21P
LDSANTURCE
PR
NY
2.600
0414
9/25
2:35P
LDSANTURCE
PR
NY
.800
0415
9/25
2:45P
LDSANTURCE
PR
NY
.400
0416
9/25
:51P
LDSANTURCE
PR
NY
2.600
0417
9/25
1P
LDSANTURCE
PR
NY
2.400
0418
9/25
:26P
LDSANTURCE
PR
NY
.600
0419
9/26
39A
LDSANTURCE
PR
NY
.400
0420
9/26
9:58A
LDSANTURCE
PR
NY
1.000
0421
9/26
10:12A
LDSANTURCE
PR
NY
1.400
0422
9/26
11:16A
LDSANTURCE
PR NY
.800
0423
9/26
12:04P
LDSANTURCE
PR
NY
.200
0424
9/26
12:12P
LDSANTURCE
PR
NY
.200
0425
9/26
12:38P
LDSANTURCE
PR
NY
.200
0426
12:46P
LDSANTURCE
PR
NY
.200
0427
9/26
11P
LDSANTURCE
PR
NY
.200
0428
9/26
:20P
LDSANTURCE
PR
NY
1.800
0429
9/26
28P
LDSANTURCE
PR
NY
.400
0430
9/26
57P
LDSANTURCE
PR
NY
.200
0431
9/26
5:00P
LDSANTURCE
PR
NY
.600
0432
9/26
10:35P
LDSANTURCE
PR
NY
.400
0433
9/27
12:08P
NEW YORK
NY
WP
3
0434
9/27
LDW PALM BCH FL
NY
0435
9/27
12
1P
INCOMING
WP
1
0436
9/27
LDW PALM BCH FL
NY
0437
9/27
3P
INCOMING
WP
1
0438
9/27
P
NEW YORK
NY
WP
1
0439
9/27
12
20P
NEW YORK
NY
WP
3
EFTA00014810

=== Page 45 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 50.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0440 9/27 12:22P
WEST PALM
FL WP
1
0441 9/27 12:23P
WEST PALM
FL WP
1
0442 9/27 12:30P
NEW YORK
NY WP
1
0443
9/27
12:31P W
INCOMING
WP
1
0444 9/27 12:33P
NEW YORK
NY WP
2
0445 9/27 12:35P
LDW PALM BCH
FL
NY
0446 9/27 12:36P
INCOMING
WP
1
0447
9/27
12:42P
NEW YORK
NY WP
1
0448 9/27 12:42P
BROOKLYN
NY WP
2
0449 9/27 12:58P
CHARLT AML
VI
WP
2
.400
0450
9/27
1:22P
LDW PALM BCH FL NY
0451
9/27
1:23P
INCOMING
WP
1
0452
9/27
1:26P
FTLAUDERDL FL WP
5
0453
9/27
4:50P
NEW YORK
NY
1
0454
9/27
4:57P
INCOMING
1
0455
9/27
5:01P
NEW YORK
NY
1
0456
9/27
5:24P
INCOMING
1
0457
9/27
7:06P
OAHU
HI
6
0458 9/28 12:01P
LOCAL
1
0459
9/28
2:05P
LOCAL
1
0460
9/28
3:03P
LOCAL
0461
9/28
3:35P
INCOMING
1
0462
9/28
5:55P
LOCAL
1
0463
9/28
5:55P
W PALM BCH FL
4
0464
9/28
6:56P
MOBILE
NY
1
0465
9/28
6:59P
NEW YORK
NY
1
0466
9/28
7:00P
MOBILE
NY
1
0467
9/28
7:06P
INCOMING
1
0468
9/28
7:11P
NEW YORK
NY
1
0469
9/28
7:31P
INCOMING
11
0470
9/28
8:11P
NEW YORK
NY
4
0471
9/28
8:15P
NEW YORK
NY
1
0472
9/28
8:15P
NEW YORK
NY
1
0473
9/28
8:15P
NEW YORK
NY
1
0474 9/28 11:07P
INCOMING
5
0475 9/29 8:57A
INCOMING
2
0476 9/29 11:18A
INCOMING
1
0477 9/29 11:23A
INCOMING
1
0478
9/29
11:40A
INCOMING
1
0479
9/29
1:00P
INCOMING
2
0480
9/29
1:23P
INCOMING
2
0481
9/29
1:31P
INCOMING
1
0482
9/29
3:36P
NEW YORK
NY
8
0483
9/29
3:48P
NEW YORK
NY
3
0484
9/29
3:58P
NEW YORK
NY
1
0485
9/29
3:59P
NEW YORK
NY
1
0486
9/29
3:59P
NEW YORK
NY
3
0487
9/29
4:09P
NEW YORK
NY
2
0488
9/29
4:22P
INCOMING
0489
9/29
6:56P
INCOMING
4
0490
9/29
7:07P
NWYRCYZN01
NY
3
0491
9/29
7:10P
NEW YORK
NY
3
0492
9/29
7:17P
INCOMING
9
0493
9/29
7:20P
INCOMING
1
0494
9/29
7:25P
INCOMING
6
0495
9/29
7:31P
INCOMING
2
0496
9/29
7:34P
INCOMING
1
0497
9/29
7:46P
INCOMING
0498
9/29
8:15P
INCOMING
0499
9/29
8:16P S
W PALM BCH FL
1
EFTA00014811

=== Page 46 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE
PAGE
51.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0500
9/29
8:17P
MOBILE
NY
1
0501
9/29
8:31P
W PALM BCH FL
3
0502
9/29
8:36P
NEW YORK
NY
1
0503
9/29
8:36P
INCOMING
2
0504
9/29
8:37P
NEW YORK
NY
4
0505
9/29
8:56P
QUEENS
NY
2
0506
9/29
9:39P
INCOMING
2
0507
9/30
12:19A
INCOMING
2
0508
9/30
6:11A
INCOMING
1
0509
9/30
7:03A D
NEW YORK
NY
2
0510
9/30
7:05A
NEW YORK
NY
2
0511
9/30
7:53A
INCOMING
1
0512
9/30
7:57A
NEW YORK
NY
1
0513
9/30
7:59A
INCOMING
1
0514
9/30
8:01A
NEW YORK
NY
1
0515
9/30
8:03A
NEW YORK
NY
1
0516
9/30
8:34A
MOBILE
NY
1
0517
9/30
8:40A
INCOMING
2
0518
9/30
8:50A
MOBILE
NY
2
0519
9/30
8:51A
NEW YORK
NY
1
0520
9/30
9:22A
INCOMING
2
0521
9/30
12:59P
LDW PALM BCH FL NY
0522
9/30
12:59P
INCOMING
WP
1
0523
9/30
2:29P
LDW PALM BCH FL NY
0524
9/30
2:30P
INCOMING
WP
1
0525
9/30
3:08P
LDW PALM BCH FL
NY
0526
9/30
3:08P
INCOMING
WP
4
0527
9/30
3:26P
LDW PALM BCH FL
NY
0528
9/30
3:27P
INCOMING
WP
1
0529
9/30
3:31P
LDW PALM BCH FL
NY
0530
9/30
3:32P
INCOMING
WP
1
0531
9/30
3:42P
LDW PALM BCH FL
NY
0532
9/30
3:44P
INCOMING
WP
1
0533
9/30
7:15P
WEST PALM
FL
WP
1
0534
9/30
8:28P
NEW YORK
NY
WP
1
0535
9/30
8:40P
LDW PALM BCH
FL
NY
0536
9/30
8:41P
INCOMING
WP
1
0537
10/01
7:49A
LDW PALM BCH FL
NY
0538
10/01
7:50A
INCOMING
WP
1
0539
10/01
8:23A
LDW PALM BCH FL
NY
0540
10/01
8:23A
INCOMING
WP
2
0541
10/01
8:53A
LDW PALM BCH FL
NY
0542
10/01
8:54A
INCOMING
WP
1
0543
10/01
8:56A
LDW PALM BCH FL
NY
0544
10/01
8:57A
INCOMING
WP
1
0545
10/01
9:24A
NEW YORK
NY
WP
4
0546
10/01
11:56A
LOCAL
1
0547
10/01
12:01P
MOBILE
NY
2
0548
10/01
12:05P
NEW YORK
NY
1
0549
10/01
12:09P
INCOMING
1
0550
10/01
12:10P
NEW YORK
NY
3
0551
10/01 12:44P
INCOMING
1
0552
10/01
12:57P
MOBILE
NY
1
0553
10/01
1:09P
INCOMING
1
0554
10/01
1:10P
MOBILE
NY
1
0555
10/01
1:11P
NEW YORK
NY
1
0556
10/01
1:15P
INCOMING
6
0557
10/01
1:48P
NEW YORK
NY
7
0558
10/01
1:58P
MOBILE
NY
1
0559
10/01
2:33P
INCOMING
1
EFTA00014812

=== Page 47 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER
BILL DATE PAGE 52.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0560
10/01
2:50P
INCOMING
1
0561
10/01
4:45P
INCOMING
7
0562
10/01
5:50P
NEW YORK
NY
2
0563
10/01
5:51P
INCOMING
13
0564
10/01
11P
LOCAL
1
0565
10/01
INCOMING
1
0566
10/01
6:13P
LOCAL
3
0567
10/01
6
INCOMING
2
0568
10/01
6
INCOMING
3
0569
10/01
7:23P
NEW YORK
NY
1
0570
10/01
7:24P
NEW YORK
NY
1
0571
10/01
7:27P
INCOMING
0572
10/01
7:28P
NEW YORK
NY
1
0573
10/01
7:32P
INCOMING
2
0574
10/01 10:22P
INCOMING
7
0575
10/02
7:47A
INCOMING
1
0576
10/02 10:10A
NEW YORK
NY
1
0577
10/02
10:10A
INCOMING
6
0578
10/02
10:23A
INCOMING
1
0579
10/02
11:15A
INCOMING
2
0580
10/02
11:23A
INCOMING
2
0581
10/02
11:38A
INCOMING
6
0582
10/02
11:44A
LOCAL
1
0583
10/02
11:46A
MOBILE
NY
1
0584
10/02
12:56P
MOBILE
NY
1
0585
10/02
1:59P
LOCAL
1
0586
10/02
2:02P
NEW YORK
NY
2
0587
10/02
2:14P
NEW YORK
NY
4
0588
10/02
:03P
INCOMING
1
0589
10/02
3:54P
INCOMING
0590
10/02
3:55P
NEW YORK
NY
1
0591
10/02
3:59P
NWYRCYZN01
NY
2
0592
10/02
4:14P
LOCAL
1
0593
10/02
4:15P
NEW YORK
NY
5
0594
10/02
4:20P
NWYRCYZN01
NY
7
0595
10/02
4:27P
LOCAL
2
0596
10/02
4:29P
NEW YORK
NY
4
0597
10/02
5:02P
MOBILE
NY
1
0598
10/02
5:02P
LOCAL
1
0599
10/02
5:03P
LOCAL
3
0600
10/02
:18P
LOCAL
1
0601
10/02
6:22P
NEW YORK
NY
5
0602
10/02
6:27P D
NEW YORK
NY
2
0603
10/02
6:29P
NEW YORK
NY
1
0604
10/02
6:35P
NEW YORK
NY
1
0605
10/02
6:44P
OAHU
HI
23
0606
10/02
6:56P
INCOMING
3
0607
10/02
7:06P
NEW YORK
NY
5
0608
10/02
7:12P
LOCAL
0609
10/02
7:12P
LOCAL
1
0610
10/02
7:16P
NEW YORK
NY
2
0611
10/02
7:17P
INCOMING
2
0612
10/02
7:20P
INCOMING
1
0613
10/02
10:12P
NEW YORK
NY
4
0614 10/02 10:32P
NEW YORK
NY
1
0615
10/02
11:12P
NEW YORK
NY
1
0616
10/03
8:48A
INCOMING
1
0617
10/03
8:53A
INCOMING
6
0618 10/03 10:01A
LOCAL
1
0619
10/03
12:00P
LOCAL
1
EFTA00014813

=== Page 48 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 53.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0620 10/03 12:01P
NEW YORK
NY
8
0621
10/03
12:09P
LOCAL
1
0622
10/03
12:10P
NEW YORK
NY
1
0623
10/03
12:21P
INCOMING
1
0624
10/03
2:20P
INCOMING
1
0625
10/03
2:44P
INCOMING
1
0626
10/03
2:50P
INCOMING
1
0627
10/03
8P
INCOMING
2
0628
10/03
:52P
INCOMING
1
0629
10/03
3:53P
LOCAL
1
0630
10/03
3:59P
S
W PALM BCH FL
1
0631
10/03
4:06P
W PALM BCH FL
2
0632
10/03
4:54P
INCOMING
4
0633
10/03
5:45P
INCOMING
1
0634
10/03
5:52P
NEW YORK
NY
3
0635
10/03
:54P
INCOMING
1
0636
10/03
:55P
NEW YORK
NY
4
0637
10/03
5:58P
LOCAL
1
0638
10/03
6:02P
NEW YORK
NY
3
0639
10/03
6:05P
NEW YORK
NY
5
0640
10/03
6:10P
INCOMING
0641
10/03
11P
NEW YORK
NY
2
0642
10/03
:12P
LOCAL
1
0643
10/03
18P
MOBILE
NY
1
0644
10/03
6:27P
NEW YORK
NY
1
0645
10/03
6:28P
MOBILE
NY
2
0646
10/03
30P
NEW YORK
NY
2
0647
10/03
6:39P
INCOMING
2
0648
10/03
6:41P
INCOMING
1
0649
10/03
6:56P
INCOMING
0650
10/03
7:10P
INCOMING
1
0651
10/03
8:02P
MOBILE
NY
1
0652
10/03
8:05P
INCOMING
2
0653
10/03
8:11P
MOBILE
NY
1
0654
10/03
8:22P
MOBILE
1
0655
10/03
8:28P
MOBILE
1
0656
10/03
8:58P
MOBILE
1
0657
10/03
9:08P
MOBILE
2
0658
10/03
9:10P
NEW YORK
1
0659
10/04
10/04
12:08A
LDW PALM BCH
NY
0660
INCOMING
WP
0661
10/04
9:15A
NEW YORK
HW
3
WP
1
0662
10/04
11:44A
LDW PALM BCH FL NY
0663
10/04
11:45A
INCOMING
WP
2
0664
10/04
11:57A
LDW PALM BCH
NY
0665
10/04
11:57A
INCOMING
NY NY NY NY NY NY NY NY NY NY NY NY FL FL FL FL FL
WP
10
0666
10/04
12:17P
INCOMING
WP
3
0667
10/04
12:21P
NEW YORK
WP
3
0668
10/04
12:40P
NEW YORK
WP
3
0669
10/04
1:19P
LDW PALM BCH
NY
0670
10/04
1:20P
INCOMING
WP
0671
10/04
6:23P
NEW YORK
WP
2
0672
10/04
6:24P
LDW PALM BCH NY
0673
10/04
6:24P
INCOMING
WP
9
0674
10/04
6:50P
LDW PALM BCH NY
0675
10/04
6:52P
INCOMING
WP
1
0676
10/04
9:05P
NEW YORK
WP
1
0677 10/04
9:25P
NEW YORK
WP
5
0678 10/04
9:36P
BROOKLYN
WP
1
0679
10/04
11:21P
NEW YORK
NY
WP
1
EFTA00014814

=== Page 49 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 54.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0680 10/05 12:24A
LDW PALM BCH NY
0681 10/05 12:24A
INCOMING
WP
8
0682
10/05
12:32A
LDW PALM BCH
NY
0683
10/05
12:32A
INCOMING
WP
5
0684
10/05
10:50A
NEW YORK
WP
1
0685
10/05
11:29A
LDW PALM BCH NY
0686
10/05
11:30A
INCOMING
WP
1
0687
10/05
11:56A
LDW PALM BCH
NY
0688
10/05
11:57A
INCOMING
WP
3
0689
10/05
12:06P
LDW PALM BCH
NY
0690
10/05
12:07P
INCOMING
WP
1
0691
10/05
12:24P
LDW PALM BCH
NY
0692
10/05
12:24P
INCOMING
WP
9
0693
10/05
12:54P
NEW YORK
WP
1
0694
10/05
2:40P
NEW YORK
WP
1
0695
10/05
4:07P
QUEENS
WP
9
0696
10/05
4:54P
D
WEST PALM
WP
2
0697
10/05
5:39P
LDW PALM BCH
NY
0698
10/05
5:41P
INCOMING
WP
1
0699
10/05
6:10P
LDW PALM BCH
NY
0700
10/05
6:11P
INCOMING
WP
1
0701
10/05
6:19P
LDW PALM BCH
NY
0702
10/05
6:19P
INCOMING
WP
4
0703
10/05
6:44P
LDW PALM BCH
NY
0704
10/05
6:45P
INCOMING
WP
1
0705
10/05
6:49P
LDW PALM BCH
NY
0706
10/05
6:50P
INCOMING
WP
1
0707
10/05
8:00P
NEW YORK
WP
1
0708
10/05
9:20P
LDW PALM BCH
NY
0709
10/05
9:21P
INCOMING
NY NY NY NY NY NY NY NY NY NY NY NY NY FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL
WP
4
0710
10/06
8:23A
NEW YORK
WP
2
0711
10/06
9:42A
LDW PALM BCH NY
0712
10/06
9:44A
INCOMING
WP
1
0713
10/06
10:28A
LDW PALM BCH
NY
0714
10/06
10:30A
INCOMING
WP
6
0715
10/06
12:06P
LDW PALM BCH
NY
0716
10/06
12:07P
INCOMING
WP
3
0717
10/06
12:17P
LDW PALM BCH
NY
0718
10/06
12:18P
INCOMING
WP
1
0719
10/06
1:17P
LDW PALM BCH
NY
0720
10/06
1:18P
INCOMING
WP
6
0721
10/06
1:33P
LDW PALM BCH
NY
0722
10/06
1:33P
INCOMING
WP
6
0723
10/06
2:24P
LDW PALM BCH
NY
0724
10/06
2:25P
INCOMING
WP
0725
10/06
2:27P
NORTHSALEM
WP
2
0726
10/06
3:01P
LDW PALM BCH
NY
0727
10/06
:01P
INCOMING
WP
2
0728
10/06
:17P
LDW PALM BCH
NY
0729
10/06
:17P
INCOMING
WP
1
0730
10/06
:41P
LDW PALM BCH
NY
0731
10/06
3:43P
INCOMING
WP
2
0732
10/06
4:31P
NEW YORK
WP
0733
10/06
5:04P
WHWNN
2
NEW YORK
WP
3
0734
10/06
5:22P
NEW YORK
WP
1
0735
10/06
:24P
NEW YORK
WP
3
0736
10/06
:26P
LDW PALM BCH
NY
0737
10/06
:27P W
INCOMING
WP
0738
32P
NEW YORK
WP
0739
10/06
:37P
QUEENS
WP
Noror
6
10/06
2
EFTA00014815

=== Page 50 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 55.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0740
10/06
6:01P
NEW ALBANY OH WP
2
0741
10/06
6:18P
BROOKLYN
NY WP
1
0742
10/06
6:19P
NEW YORK
NY WP
1
0743
10/06
6:21P
BROOKLYN
NY WP
1
0744
10/06
6:24P
NEW YORK
NY WP
9
0745
10/06
8:58P
LOCAL
1
0746
10/06
9:01P
INCOMING
3
0747
10/06
9:08P
MOBILE
NY
3
0748
10/06
9:10P
A
MOBILE
NY
5
0749
10/06
9:26P
NEW YORK
NY
4
0750
10/06
9:29P
FTLAUDERDL FL
2
0751
10/06
9:30P
INCOMING
2
0752
10/06
9:32P
FTLAUDERDL FL
0753
10/06
9:38P
DURHAM
NC
1
0754
10/06
9:42P
INCOMING
1
0755
10/06
9:47P
INCOMING
8
0756
10/06
9:48P
INCOMING
0757 10/06 10:02P
INCOMING
3
0758
10/06
10:12P
INCOMING
0759
10/06
11:22P
LOCAL
2
0760
10/07
8:41A
INCOMING
0761
10/07
9:11A
INCOMING
3
0762
10/07
9:24A
INCOMING
1
0763
10/07
9:44A
INCOMING
0764 10/07 11:19A
NEW YORK
NY
6
0765 10/07 11:31A
LOCAL
2
0766
10/07
11:53A
INCOMING
2
0767
10/07
12:27P
INCOMING
0768
10/07
12:44P
INCOMING
1
0769
10/07
2:05P
LOCAL
0770
10/07
2:20P
FTLAUDERDL FL
2
0771
10/07
2:49P
INCOMING
5
0772
10/07
3:16P
INCOMING
1
0773
10/07
3:31P
FTLAUDERDL FL
7
0774
10/07
3:48P
INCOMING
1
0775
10/07
6:03P
NEW YORK
NY
3
0776
10/07
6:41P
MOBILE
NY
1
0777
10/07
6:46P
INCOMING
1
0778
10/07
6:58P
INCOMING
0779
10/07
7:29P
INCOMING
2
0780
10/07
7:32P
NEW YORK
NY
2
0781
10/07
7:34P
NEW YORK
NY
10
0782
10/07
8:24P
INCOMING
1
0783
10/08
8:38A
INCOMING
1
0784
10/08
8:38A
INCOMING
1
0785
10/08
8:45A
NWYRCYZN01 NY
2
0786
10/08
9:06A
INCOMING
1
0787
10/08
9:34A
INCOMING
1
0788
10/08
10:45A
NEW YORK
NY
0789 10/08 10:45A
NEW YORK
NY
2
0790 10/08 10:47A
LOCAL
1
0791 10/08 10:48A
NEW YORK
NY
2
0792 10/08 10:59A
INCOMING
1
0793
10/08
11:25A
LOCAL
1
0794
10/08
1:03P
INCOMING
4
0795
10/08
1:37P
INCOMING
2
0796
10/08
1:44P
INCOMING
1
0797
10/08
2:04P
INCOMING
0798
10/08
2:11P
INCOMING
0799
10/08
3:27P
INCOMING
1
EFTA00014816

=== Page 51 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 56.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0800
10/08
3:47P
INCOMING
1
0801
10/08
4:10P
INCOMING
1
0802
10/08
4:47P
LOCAL
2
0803
10/08
4:48P
NEW YORK
NY
2
0804
10/08
4:51P
NWYRCYZN01
NY
2
0805
10/08
4:54P
NEW YORK
NY
2
0806
10/08
4:55P
NEW YORK
NY
0807
10/08
4:56P
NEW YORK
NY
0808
10/08
4:57P
INCOMING
1
0809
10/08
INCOMING
3
0810
10/08
5:07P
INCOMING
4
0811
10/08
INCOMING
0812
10/08
INCOMING
2
0813
10/08
INCOMING
2
0814
10/08
7:12P
INCOMING
2
0815
10/08
7:13P D
NEW YORK
NY
3
0816
10/08
7:16P
NEW YORK
NY
2
0817
10/08
6P
INCOMING
2
0818
10/08
7:54P
MOBILE
NY
0819
10/08
8
05P
INCOMING
3
0820
10/08
8
:19P
INCOMING
2
0821
10/08
8:36P
MOBILE
NY
0822
10/08
8:49P
NEW YORK
NY
0823
10/08
8:55P
MOBILE
NY
2
0824
10/08
9:09P
INCOMING
1
0825
10/08
NEW YORK
NY
0826
10/08
1P
W PALM BCH FL
3
0827
10/09
1:01A
LOCAL
2
0828
10/09
8:36A
INCOMING
6
0829
10/09
8:42A
NEW YORK
NY
0830
10/09
10:43A
INCOMING
4
0831
10/09
1:34P
INCOMING
3
0832
10/09
1:37P
INCOMING
3
0833
10/09
INCOMING
4
0834
10/09
INCOMING
1
0835
10/09
6P
INCOMING
2
0836
10/09
20P
NEW YORK
NY
2
0837
10/09
3:41P
LOCAL
0838
10/09
3:42P
NEW YORK
NY
2
0839
10/09
3:58P
INCOMING
0840
10/09
3:59P
INCOMING
1
0841
10/09
4:00P
NEW YORK
NY
4
0842
10/09
4:05P
NEW YORK
NY
4
0843
10/09
4:09P
NEW YORK
NY
1
0844
10/09
4:10P
INCOMING
1
0845
10/09
4:13P
INCOMING
1
0846
10/09
4:25P
INCOMING
0847
10/09
4:27P
NEW YORK
NY
1
0848
10/09
4:28P
NEW YORK
NY
0849
10/09
4:28P
NEW YORK
NY
1
0850
10/09
4:29P
NEW YORK
NY
0851
10/09
4:30P
NEW YORK
NY
3
0852
10/09
4:42P
INCOMING
0853
10/09
4:48P
INCOMING
4
0854
10/09
4:52P
NEW YORK
NY
3
0855
10/09
4:55P
NEW YORK
NY
2
0856
10/09
4:57P
LOCAL
2
0857
10/09
4:59P
LOCAL
0858
10/09
5:05P
INCOMING
1
0859
10/09
5:07P
NEW YORK
NY
13
EFTA00014817

=== Page 52 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 57.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0860
10/09
5:22P
INCOMING
1
0861 10/09
5:32P
INCOMING
2
0862
10/09
6:48P
NWYRCYZN01 NY
2
0863
10/09
6:58P
INCOMING
2
0864
10/09
7:00P
NEW YORK
NY
2
0865
10/09
7:11P
NEW YORK
NY
0866
10/09
7:34P
LOCAL
1
0867
10/09
7:35P
NEW YORK
NY
1
0868
10/09
7:36P
NEW YORK
NY
2
0869
10/09
7:37P
NEW YORK
NY
3
0870
10/09
7:42P
MOBILE
NY
2
0871
10/09
7:44P
W PALM BCH FL
0872
10/09
7:44P
in
W PALM BCH FL
0873
10/09
7:54P
LOCAL
1
0874
10/09
7:54P
INCOMING
1
0875
10/09
7:57P
INCOMING
2
0876
10/09
8:57P
NWYRCYZN01 NY
1
0877
10/09
8:57P
LOCAL
2
0878
10/09
9:00P
W PALM BCH FL
4
0879
10/09
9:04P
INCOMING
10
0880
10/09
9:14P
NEW YORK
NY
0881 10/09
9:18P
INCOMING
5
0882
10/09
9:22P
MOBILE
NY
1
0883
10/09
9:25P
MOBILE
NY
1
0884
10/09
9:31P
NEW YORK
NY
2
0885
10/09
9:45P
INCOMING
1
0886
10/09
10:15P
LOCAL
0887
10/09
10:16P
NEW YORK
NY
3
0888
10/09
11:17P
INCOMING
0889
10/09
11:23P
NEW YORK
NY
0890
10/10
12:59A
NEW YORK
NY
0891
10/10
9:24A
INCOMING
0892
10/10
11:19A
INCOMING
0893
10/10
12:18P
INCOMING
5
0894
10/10
12:43P
INCOMING
3
0895
10/10
1:35P
LOCAL
0896
10/10
2:01P
INCOMING
3
0897
10/10
2:10P
INCOMING
3
0898
10/10
3:53P
INCOMING
0899
10/10
4:48P
INCOMING
0900
10/10
5:02P
INCOMING
3
0901
10/10
6:06P
INCOMING
0902
10/10
6:11P
INCOMING
2
0903
10/10
7:11P
INCOMING
2
0904
10/10
7:28P
NEW YORK
NY
1
0905
10/10
7:29P
NWYRCYZN01
NY
14
0906
10/10
7:44P
Il
NEW YORK
NY
2
0907
10/10
7:47P
INCOMING
1
0908
10/10
7:57P
MOBILE
NY
0909
10/10
7:57P
NEW YORK
NY
2
0910
10/10
8:00P
INCOMING
2
0911
10/10
8:22P
INCOMING
0912
10/10
8:32P
INCOMING
5
0913
10/10
8:37P
INCOMING
3
0914
10/10
8:39P
NEW YORK
NY
0915
10/10
8:39P
NEW YORK
NY
6
0916
10/10
8:50P
NEW YORK
NY
2
0917
10/10
8:53P
INCOMING
0918
10/10
9:24P
LOCAL
0919
10/10
:25P
ECUADOR
2
1.300
EFTA00014818

=== Page 53 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 58.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0920
10/10
9:27P
NEW YORK
NY
1
0921
10/10
9:29P
NEW YORK
NY
1
0922
10/10
9:44P
INCOMING
1
0923
10/11
6:58A
INCOMING
1
0924
10/11
9:48A
INCOMING
9
0925
10/11
11:21A
INCOMING
1
0926
10/11
12:27P
NEW YORK
NY
0927
10/11
12:31P
NEW YORK
NY
5
0928
10/11
1:20P
LOCAL
0929
10/11
1:41P
INCOMING
0930
10/11
1:42P
S
W PALM BCH FL
0931
10/11
1:43P
W PALM BCH FL
0932
10/11
NEW YORK
NY
0933
10/11
INCOMING
0934
10/11
:57P
MOBILE
NY
3
0935
10/11
NEW YORK
NY
3
0936
10/11
INCOMING
0937
10/11
:02P
W
NEW YORK
NY
0938
10/11
NEW YORK
NY
0939
10/11
OP
QUEENS
NY
2
0940
10/11
LOCAL
0941
10/11
S
W PALM BCH FL
0942
10/11
MOBILE
NY
0943
10/11
NEW YORK
NY
0944
10/11
20P
INCOMING
0945
10/11
INCOMING
0946
10/11
4:50P
NEW YORK
NY
0947
10/11
4:58P D
NEW YORK
NY
2
0948
10/11
5:01P
NEW YORK
NY
1
0949
10/11
:03P
NEW YORK
NY
0950
10/11
:03P
QUEENS
NY
0951
10/11
QUEENS
NY
2
0952
10/11
NEW YORK
NY
0953
10/11
:55P
NWYRCYZN01
NY
2
0954
10/11
8:00P
LOCAL
2
0955
10/11
NEW YORK
NY
0956
10/11
LOCAL
2
0957
10/11
10:05P
INCOMING
0958
10/11
10:46P
FTLAUDERDL FL
9
0959
10/11
11:21P
FTLAUDERDL FL
4
0960
10/11
25P
LOCAL
0961
10/12
:02A
INCOMING
2
0962
10/12
:06A
W PALM BCH FL
0963
10/12
1:20P
INCOMING
0964
10/12
LOCAL
1
0965
10/12
28P
INCOMING
0966
10/12
28P
W PALM BCH FL
3
0967
10/12
:32P
NEW YORK
NY
3
0968
10/12
:35P
W PALM BCH FL
0969
10/12
INCOMING
3
0970
10/12
NEW YORK
NY
3
0971
10/12
INCOMING
0972
10/12
NEW YORK
NY
0973
10/12
QUEENS
NY
0974
10/12
P
NEW YORK
NY
3
0975
10/12
3
P
INCOMING
2
0976
10/12
P
NEW YORK
NY
0977
10/12
6
NEW YORK
NY
0978
10/12
P
NEW YORK
NY
2
0979
10/12
4:
03
P
INCOMING
1
EFTA00014819

=== Page 54 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 59.0
JEFFREY E EPSTEIN &
OCT 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0980
10/12
4:07P
LOSANGELES CA
3
0981 10/12 4:11P
WLOSANGELS CA
2
0982 10/12 4:13P
W PALM BCH FL
1
0983 10/12 5:31P
LOCAL
2
0984 10/12 5:37P
NEW YORK
NY
2
0985 10/12 5:40P
W PALM BCH FL
2
0986 10/12 6:36P
LOCAL
1
0987 10/12 9:50P
LOCAL
1
0988 10/12 10:37P
INCOMING
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
2030
.00
38.30
CALL CHARACTERISTICS
D = AT&T Connect Calls, W = Call Waiting,
S = Long Distance Service Billed Separately,
A = Automatic Dropped Call Credit
"CALLS FROM" KEY:
NY = NEW YORK
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001 9/16 8:48A
10
0002
9/17
12:48P
.10
0003 9/17 12:58P
.10
0004
9/17
1:37P
.10
0005 9/17 3:11P
10
0006
9/21
2:46P
.10
0007 9/24 12:11P
10
0008
9/28
3:37P
.10
0009 9/30 11:55A
.10 0010 10/01 12:45P
.10
0011 10/01 12:48P
.10
0012
10/03
2:43P
.10
0013 10/08 6:28P
.10 0014 10/09 2:25P
.10
0015 10/09 3:37P
.10 0016 10/09 4:35P
.10
0017 10/10 9:51A
10 0018 10/11 3:42P
.10
0019 10/11 4:42P
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
1.90
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: USVI, VI
0001 9/22 11:28A
NEW YORK C NY
1
.69
0002 9/22 11:29A
NEW YORK
NY
5
3.45
1.00
0003
9/22 11:46A
QUEENS
NY
1
.69
.20
0004 9/22 12:16P
INCOMING
1
.69
0005 9/22 2:21P
NEW YORK C NY
1
.69
EFTA00014820

=== Page 55 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 60.0
JEFFREY E EPSTEIN &
OCT 14, 2003
REF
DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0006
9/22
5:05P
INCOMING
1
.69
0007
9/22
6:30P
INCOMING
4
2.76
0008
9/22
6:34P
NEW YORK
NY
1
.69
.20
0009
9/23
11:34A
NEW YORK
00
NY
1
.69
0010
9/23
12:35P
NEW YORK
C
NY
2
1.38
0011
9/23
2:28P
BROOKLYN
NY
1
.69
.20
0012
9/23
2:45P
INCOMING
2
1.38
0013
9/23
3:21P
BROOKLYN
NY
5
3.45
1.00
0014
9/23
3:28P
BROOKLYN
NY
9
6.21
1.80
0015
9/23
3:37P
NEW YORK C NY
1
.69
0016
9/24
12:59P
INCOMING
5
3.45
0017
9/24
1:17P
NEW YORK C NY
2
1.38
0018
9/24
2:53P
INCOMING
4
2.76
0019
9/24
3:10P
INCOMING
1
.69
0020
9/24
3:12P
CHARLT AML VI
3
2.07
.60
0021
9/24
3:34P
NEW YORK C NY
1
.69
0022
9/24
3:52P
0023
9/24
7:45P
NEW YORK
NEW YORK CC C NY
2
1.38
C
NY
1
.69
0024
9/25
12:51P
INCOMING
11
7.59
0025
9/25
1:07P
INCOMING
1
.69
0026
9/25
1:25P
INCOMING
1
.69
0027
9/25
1:39P
C ST CROIX VI
1
.69
.20
0028
9/25
2:21P
INCOMING
13
8.97
0029
9/25
2:35P
INCOMING
4
2.76
0030
9/25
2:46P
INCOMING
2
1.38
0031
9/25
2:52P
INCOMING
0032
9/25
3:12P
13
8.97
INCOMING
8.28
0033
9/25
3:26P
INCOMING
2
1.38
0034
9/26
9:40A
INCOMING
2
1.38
0035
9/26
9:58A
INCOMING
5
3.45
0036
9/26
10:13A
INCOMING
7
4.83
0037
9/26
11:17A
INCOMING
4
2.76
0038
9/26
12:06P
INCOMING
1
.69
0039
9/26
12:13P
INCOMING
1
.69
0040
9/26
12:38P
INCOMING
1
.69
0041
9/26
12:47P
INCOMING
1
.69
0042
9/26
3:12P
INCOMING
1
.69
0043
9/26
3:20P
INCOMING
9
6.21
0044
9/26
3:29P
INCOMING
2
1.38
0045
9/26
3:59P
INCOMING
1
.69
0046
9/26
5:02P
INCOMING
3
2.07
0047 9/26 10:35P
INCOMING
2
1.38
0048 9/27 9:24A
NEW YORK
NY
2
1.38
.40
Subtotal for : USVI, VI
157
108.33
5.60
.00
TOTAL ROAMING CHARGES
157
108.33
5.60
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
LAST
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
PAGE
EFTA00014821


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: FW: Ghislaine Maxwell Triggerfish
Date: Wed, 23 Dec 2020 19:42:21 +0000
do you need the seal on the DNH triggerfish warrant extended?
Merry Christmas to you and yours!
Mr.
From:
Sent: Wednesday, December 23, 2020 10:20 AM
To:
Subject: Ghislaine Maxwell Triggerfish
1
The seal on this triggerfish is set to expire soon.
Am I correct in assuming we can go ahead and let this lapse?
EFTA00016795


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=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
December 18, 2020
BY ELECTRONIC MAIL
Cohen & Gresser LLP
New York, NY 10022
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Due to an inadvertent error in Bates stamping in prior productions, which the Government
just discovered, today we are reproducing the materials listed in the below index. These items
were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have
now been corrected. These discovery materials are now stamped with the correct control numbers
SDNY_GM_02742184 through SDNY_GM_02742302.
An index of the replacement materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
Reproduction, Deutsche Bank materials
SDNY GM 02742184
SDNY GM 02742186
relating to Jeffrey Epstein
Reproduction, UBS Subpoena Return, 12-15-
SDNY GM 02742187
SDNY GM 02742302
2020
EFTA00016032

=== Page 2 ===
Page 2
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
EFTA00016033


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: FCA
Date: Mon, 03 Feb 2020 21:08:36 +0000
Sorry to miss you - am free til 5 and again after 6. Let me know if you're around.
From:
(USANYS)
Sent: Monday, February 3, 2020 12:09 PM
To:
(USANYS)
Subject: Re: FCA
Just tried you. Will swing by later
Sent from my iPhone
On Feb 3, 2020, at 11:28 AM,
(USANYS)
wrote:
Hey
- We got a few follow up questions from the FCA on Epstein and wanted to run something by you. Let me
know if you have a moment to discuss. Thanks,
EFTA00016821


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
,
(USANYS)"
Cc:
"
(USANYS)"
Subject: RE: Epstein
Date: Thu, 06 Dec 2018 23:59:48 +0000
Importance: Normal
Yeah, we have a Google Alert set up so we're getting a feed of everything Epstein-related. It's a flood this week.
From:
(USANYS)
Sent: Thursday, December 06, 2018 18:55
To:
)
>;
-
>;
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein
Sorry, hit send too soon:
https://www.nbcnews.com/news/us-news/lawmakers-demand-probe-sex-offender-jeffrey-epstein-s-sweetheart-deal-
n944516
From:
(USANYS)
Sent: Thursday, December 6, 2018 6:55 PM
To:
>;
)
>;
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein
Thanks. Unrelated, did you see this:
From:
Sent: Thursday, December 6, 2018 6:52 PM
To:
(USANYS)
is
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein
Yes, it's 2018R01618
From:
(USANYS)
Sent: Thursday, December 06, 2018 18:51
To:
)
is
)
>;
(USANYS)
EFTA00016453

=== Page 2 ===
Cc:
(USANYS)
Subject: Epstein
Do you guys have a USAO # yet?
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00016454


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Sun, 24 Mar 2019 20:08:43 +0000
Importance: Normal
Thanks, and sounds good. And
and I chatted a bit about his conversation with Kaplan -
let me know if/when
you get back to her, and happy to circle up to talk further thereafter.
From:
Sent: Sunday, March 24, 2019 3:53 PM
To:
is
>;
Cc:
Subject: RE: Epstein
It was good, for the most part. Making progress.
and I interviewed two witnesses on Friday at the BSF office in Fort
Lauderdale. The third witness we were supposed to interview decided not to come at the last minute, because she
decided she didn't want to be involved in the case after all this time has passed. She was not someone we were focused
on at this stage, so while we may circle back at another time to see if she comes in, right now it's fine.
We had a call with an attorney who represented FL victims a decade ago, and we're coordinating with him to schedule
follow up interviews with two of the witnesses who were approached and said they weren't sure how the civil case their
lawyer handled affected if they could talk to us.
had a call with Robbie Kaplan right before the trip, and the upshot is we are making baby steps towards an interview
with
They are concerned about her exposure, so we are discussing ways of addressing that, and the next
step will likely be an attorney proffer.
From:
Sent: Sunday, March 24, 2019 3:40 PM
To:
is
>;
Cc:
Subject: Epstein
How did the rest of the trip go?
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00015003


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c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein PR Final review
Date: Mon, 08 Jul 2019 14:21:38 +0000
Importance: Normal
Thanks
From:
(USANYS)
Sent: Monday, July 8, 2019 10:21 AM
To:
(USANYS)
Subject: RE: Epstein PR Final review
I am signed off.
From:
(USANYS)
Sent: Monday, July 8, 2019 10:17 AM
To:
(USANYS)
>;
(USANYS)
V.
(USANYS)
is
(USANYS)
is
(USANYS)
in
is
>;
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Any other edits? Or are we good to finalize the release?
From:
(USANYS)
Sent: Monday, July 8, 2019 9:55 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Also in
quote: Are we trying to say no matter where the incident took place?
FBI Assistant Director
said: "We are asking anyone who may have been victimized
by Jeffery Epstein, or anyone who may have information about his alleged criminal behavior, to please call us.
The number is 1-800-CALL-FBI. We want to hear from you, regardless of the age you are now, or whatever age
you were then, no matter the incident that took place. The bravery it takes to call us might empower others to
speak out about the crimes committed against them. It is important to remember there was never, nor will
there ever be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come first."
EFTA00014643

=== Page 2 ===
From:
(USANYS)
Sent: Monday, July 8, 2019 9:39 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
is
Cc:
(USANYS) [Contractor]
>;
(USANYS)
Subject: Epstein PR Final review
Importance: High
Attached is the final PR for review. Please note that
quote includes the number to call, so we need to
finalize that as soon as possible. Thanks.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00014644


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=== Page 1 ===
From:
"
To:
Subject: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
Date: Fri, 18 Dec 2020 02:21:10 +0000
FWIW
https://okmagazine.com/exclusives/jeffrey-epstein-video-recordings-darren-indyke/
Sent from my iPhone
EFTA00016116


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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Letter
Date: Fri, 02 Oct 2020 13:11:31 +0000
Attachments: 2020.10.1_Letter_to_Government_re__Discovery.PDF
Inline-Images: image005.jpg;image006.jpg
You guys have some time to discuss this later today?
From: Christian Everdell
Sent: Thursday, October 1, 2020 11:11 PM
To:
Subject: Letter
Please see the attached letter.
Regards,
Chris
Christian Everdell
COHEN & GRESSER LLP
New York
Seoul
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00014585


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c0:
=== Page 1 ===
From
To
Central
Subject: RE: mail sent last week
Date: Tue, 02 Nov 2021 13:14:14 +0000
Attachments: 2021-11-01_GM_letter_re_MDC_legal_mail_v3.docx.
Sorry, take a look at this version
EFTA00016201

=== Page 2 ===


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=== Page 1 ===
The Cameo Collection of Blank Books
Cameo
2
Editions
W.E. Associates Ltd.
Alpha House, Unit 1, Marshgate, Stratton Road
Swindon, Wilts, SNI 2PA England
ISBN 1-85867-023-3
Printed in U.S.A.
Product of Mexico
ISBN I 85867 023 3
9 781858 670232


c1: EFTA00015948
c2: DataSet 8
c3: VOL00008
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein / Maxwell Case
Date: Mon, 13 Jul 2020 17:17:22 +0000
Of course, absolutely, and thanks. I think whatever you feel would be appropriate, and certainly no problem in thanking
her for being in touch and to generally be supportive, whether or not she ultimately is interested in sharing anything
more. Happy to discuss further if that's useful but yes, please do feel totally free to acknowledge.
From:
Sent: Monday, July 13, 2020 13:15
To:
Subject: FW: Epstein / Maxwell Case
I would like to acknowledge her email if you let me.
From:
Sent: Monday, July 13, 2020 1:03 PM
To:
Subject: Epstein / Maxwell Case
Hello,
I've debated whether to send this email a thousand times. In fact, I've written it numerous times. Hopefully I
will be brave enough to send it this time.
My name is
I was sexually assaulted when I was barely 18 years old in a NYC
restaurant / club. At the time, I was too scared and confused and well traumatized to do anything about it. My
life pretty much crumbled after that. And by the time I pulled myself together, it was too late to do anything
about it Or at least I felt it was. I had done such a good job, eradicating anything associated with that part of
my life and scrubbing my mind of the memories that I no longer remembered the details like the name of the girl
that invited me along and introduced me to the person who assaulted me as well as the name or location of the
venue. So I did nothing
A few months ago, I saw Epstein's face on the news and I put everything altogether.. I was sexually assaulted by
Jeffery Epstein.
He's dead now. so I'm not really sure why I'm emailing or even bringing it up now but I just felt like I should let
someone know. If I can be of help in anyway, I'd like to be. However, I don't really have proof and I can't really
offer anything as far as Maxwell's case goes. She could have been there as well as I do remember there being a
"woman" there along with numerous other "girls". I remember making a mental note to myself how it was weird
that there that I was probably the oldest one out of the girls that were there except for the one woman that was
sitting with the other men.
Anyway, for now, I'd prefer to talk via email but if it makes sense, I'd be okay chatting with you in the future if
you think it makes sense. Again, I'm not sure if I can be of any help or if it even makes sense to reach out
anymore. but I just felt like I'd never forgive myself if I stayed silent again this time.
EFTA00015948

=== Page 2 ===
Thank you.
Sincerely,
EFTA00015949


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Update
Date: Sat, 14 Nov 2020 00:59:29 +0000
Thanks very much, that's great news. I'll let the team know and ask them to hold off until next week to touch base.
Have a great weekend.
From
Sent: Friday, November 13, 2020 3:57 PM
To:
Cc:
Subject: Update
Just following up from our last conversation.
will be assigned on a full time basis to the
Epstein case until further notice and
will be helping out on a part time basis. Please hold off on
having anyone from SDNY reach out to them until next week so
has time to get them briefed. Their
contact information is below. Any questions let me know. Have a good weekend.
Thanks
SOS
IA
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=== Page 1 ===
From: "
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein 6(e) app .docx
Date: Wed, 29 Jan 2020 14:54:16 +0000
Attachments: 2019.12.19_Epstein_6(e)_App_&_Order.docx
Here you go
From:
(USANYS)
Sent: Wednesday, January 29, 2020 9:33 AM
To: N
ANYS)
Subject: Epstein
Will come by in a second.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
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=== Page 1 ===
From:
)"
To: "
Subject: RE: Epstein
Date: Thu, 01 Aug 2019 13:51:10 +0000
Thank you!
Original Message
From:
Sent: Thursday, August 1, 2019 9:40 AM
To:
)
Subject: Epstein
I'll have the reports tomorrow but I have a preliminary of the interviews
Sent from my iPhone
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
Defendant.
:
:
:
X
GHISLAINE MAXWELL'S MOTION TO EXCLUDE ANY EVIDENCE OFFERED BY
THE GOVERNMENT PURSUANT TO FED. R. EVID. 404(b) FOR FAILURE TO
COMPLY WITH THE RULE'S NOTICE REQUIREMENT
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Denver, CO 80203
Phone:
Christian R. Everdell
COHEN & GRESSER LLP
York, NY 10022
Phone:
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Phone:
Attorneys for Ghislaine Maxwell
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=== Page 2 ===
TABLE OF CONTENTS
BACKGROUND
1
I.
2020 Amendments to Rule 404(b)
1
II. Rule 404(b) Notice in This Case
2
ARGUMENT
4
I.
By Failing to Comply with the Rule 404(b) Notice Requirement, the Government Has
Waived the Admission of Any Evidence Pursuant to the Rule
4
II. Should the Government's Failure Be Excused, Ms. Maxwell Requests an Opportunity to
Rebut any Proffered Non-Propensity Purpose and Basis
5
III. Ms. Maxwell Needs Additional Time to Respond to the Scant Notice that the Materials
Qualify as "Direct Evidence" in the Case
6
CONCLUSION
7
i
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=== Page 3 ===
TABLES OF AUTHORITIES
Cases
United States V. Brand, 467 F.3d 179 (2d Cir. 2006)
4
United States V. Bui, 859 F. App'x 610 (2d Cir. 2021)
4
Other Authorities
Wright & Miller, 22B Fed. Prac. & Proc. Evid., $ 5242.1 2020 Amendments to Rule 404(b)
(2021)
2,6
Rules
Fed. R. Evid. 404(b)
passim
ii
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Ghislaine Maxwell moves in limine to exclude any evidence the Government seeks to
admit at trial under Fed. R. Evid. 404(b) (the "Rule"). That Rule, as amended in December
2020, expressly requires particularized notice to the defense of the exact evidence to be offered,
an articulated non-propensity purpose for its admission, and the reasoning supporting that
purpose. Despite notice of the rule change and an opportunity to comply with the Rule by this
Court's deadline of October 11, the Government opted not to follow the requirements of the Rule
and should now be foreclosed from offering any evidence pursuant to Rule 404(b).
BACKGROUND
I. 2020 Amendments to Rule 404(b)
Rule 404 sets forth the requirements for "Notice in a Criminal Case" of an intent to
introduce evidence under the rule:
"In a criminal case, the prosecutor must:
(A) provide reasonable notice of any such evidence that the prosecutor intends to offer at
trial, so that the defendant has a fair opportunity to meet it;
(B) articulate in the notice the permitted purpose for which the prosecutor intends to offer
the evidence and the reasoning that supports the purpose; and
(C) do so in writing before trial - or in any form during trial of the court, for good cause,
excuses lack of pretrial notice."
Fed. R. Evid. 404(b)(3). In December 2020, the Rule was "amended principally to
impose additional notice requirements in a criminal case." Fed. R. Evid. 404, Advisory
Committee Notes, 2020 Amendments. Prior to the rule change, the prosecution needed only to
give notice of the "general nature" of the anticipated evidence; thus, "some courts permit[ted]
the government to satisfy the notice obligation without describing the specific act that the
evidence would tend to prove, and without explaining the relevance of the evidence for a non-
propensity purpose" (id.).
1
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After December 2020, according to the Advisory Committee, the new subsection (B)
requires that:
The prosecution must not only identify the evidence that it intends to offer
pursuant to the rule but also articulate a non-propensity purpose for which the
evidence is offered and the basis for concluding that the evidence is relevant in
light of this purpose.
Id. (emphasis added). The Rule's requirement that the prosecution must "identify the evidence,"
"articulate a non-propensity purpose" and a "basis for concluding the evidence is relevant in light
of this purpose" replaced the previous notice requirement only of the "general nature" of
anticipated evidence. The "advance notice" is "important so that the parties and the court have
adequate opportunity to assess the evidence, the purpose for which it is offered, and whether the
requirements of Rule 403 have been satisfied
Id.
The new rule also required that the pre-trial notice be done in writing, "sufficiently ahead
of trial to give the defendant a fair opportunity to meet the evidence." Rule 404(b)(3)(A). "The
'air opportunity' must include sufficient time for an independent investigation that might surface
evidence that refutes, mitigates, or places the other act in a different light. Prosecutors who cut
the disclosure too close to the trial date risk a judge either excluding the evidence so that the trial
can proceed as scheduled or delaying the trial so the defense can "meet" the other act proof. Easy
to overlook is that the judge too needs time to consider the admissibility of the other act
evidence." See Wright & Miller, 22B Fed. Prac. & Proc. Evid., § 5242.1 2020 Amendments to
Rule 404(b) (2021).
II. Rule 404(b) Notice in This Case
The Government advised this Court that it could provide notice of any Rule 404(b)
evidence by 45 days prior to trial, which would afford it "adequate time to finalize its
determination of what evidence it will seek to introduce at trial pursuant to" the Rule. See Dkt.
2
EFTA00016210

=== Page 6 ===
229 at 3. This Court then ordered the Government to provide disclosure of any "Rule 404(b)
evidence and notice" by October 11. Dkt. 297.
On October 11, 2021, the Government served on defense counsel a short letter entitled
the "Maxwell Rule 404(b) letter" (the "Rule 404(b) Letter" or the "Letter"), attached as Exhibit
A. In it, the Government referenced two sets of evidence: (a) certain emails purportedly between
Ms. Maxwell and third-party "influential" men whom she allegedly tried to set up on dates, and
(b) a witness,
a woman who worked for Epstein between 2005-06 (after the
conclusion of the charged conspiracy) whom the Government said it "may call" at trial. The
Government asserted in the Letter that the evidence collectively was, in its opinion, "direct
evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the
defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of (sic)
accident." Id. at 2. The Government stated it would not be moving in limine to seek the
evidence's admission "[b]ecause this evidence is admissible as direct evidence." Id. The Letter
lacked identification of any particular purpose for these two categories of evidence and lacked
any "basis for concluding that the evidence is relevant in light of this purpose."
Also on October 11, the Government provided its anticipated trial exhibits. Even a quick
review of those exhibits reflects the Government's apparent intent to offer numerous documents
and other evidence that purportedly occurred after the conclusion of the charged conspiracy.
See, e.g., GX-4-D through GX-4-K (message pads dated beginning in 2005); GX-423 (an
Amazon shipment to Jeffrey Epstein of an iPhone USB lightning cable in 2013); GX-501 & 502
(financial statements from June 2007); GX-661 & 662 (flight logs from 2005-13). None of these
items of evidence were mentioned in the Maxwell Rule 404(b) Letter. The Government's theory
of admissibility concerning this post-2004 evidence remains unclear.
3
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=== Page 7 ===
ARGUMENT
I. By Failing to Comply with the Rule 404(b) Notice Requirement, the
Government Has Waived the Admission of Any Evidence Pursuant to the
Rule
Under the version of Rule 404(b) in effect for this trial, the Government was required to
specifically "identify" any evidence it intends to offer under the Rule, to "articulate... the
permitted purpose for which" the identified evidence will be offered, and to state the "reasoning
that supports the purpose." The Government did not timely comply with these requirements and
should therefore be precluded from offering any evidence under Rule 404(b).
To be sure, the Rule 404(b) Letter did "identify" several emails purportedly between Ms.
Maxwell and two other adult men that discuss fixing them up with women on a date. But even
though the Government claimed these emails may be admissible "in the alternative, pursuant to
Rule 404(b)," there is nothing in the Letter which states the permitted purpose for which they
might be offered, nor the "reasoning that supports that purpose." Ms. Maxwell is unable to guess
which of the laundry list of potential purposes contained in Rule 404(b) might serve as the
grounds, and she certainly is not able to guess the Government's "reasoning." Without the
required notice, both defense counsel and the Court cannot undertake the required analysis to
determine whether the evidence is being offered for a proper non-propensity purpose, is relevant
to a disputed issue, can satisfy a Rule 403 analysis, or needs a limiting instruction. United States
V. Bui, 859 F. App'x 610 (2d Cir. 2021) (summary order) (quoting United States V. Brand, 467
F.3d 179, 196 (2d Cir. 2006)).
The Government likewise did "identify" Ms.
as a potential witness and offered
two, non-exclusive potential topics of her testimony. The Government advised that she will
testify about, "among other things, [i] certain [unspecified] documentary evidence relating to the
4
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charged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey
Epstein with underage girls," apparently in 2005-06. This is hardly the type of "identif[ied]"
evidence the Rule contemplates. What "documentary evidence" will she testify about? What
"role" did she play in scheduling massages after the conclusion of the charged conspiracy? For
what purpose will she testify to it? Are there other topics covered by the language "among other
things" that the Government submits is admissible under Rule 404(b)? What is it? What is the
purpose of it? Will it be offered to prove Ms. Maxwell's "intent, preparation, plan, knowledge,
identity and/or absence of mistake of [sic] accident" or something else? How is it permissible
non-propensity evidence?
Finally, by failing to identify the numerous exhibits that fall after the period of the
conspiracy in the Rule 404(b) Letter, the Government has also waived any right to argue that
those documents should be admitted under the rule as well.
The entire point of the change to Rule 404(b), and this Court's scheduling Order, is to
permit Ms. Maxwell to investigate, analyze, dispute, move in limine if appropriate, or rebut the
proffered Rule 404(b) evidence. There is nothing in Rule 404(b) that excuses the required
Notice in the event the Government only offers the evidence "in the alternative" under the rule.
By disregarding the requirements of Rule 404(b), the Government has chosen to deprive Ms.
Maxwell of her right to dispute the admissibility of this evidence.
II. Should the Government's Failure Be Excused, Ms. Maxwell Requests an
Opportunity to Rebut any Proffered Non-Propensity Purpose and Basis
Because the Government has not identified the non-propensity purpose nor reasoning
underlying the admission of any Rule 404(b) evidence, the defense is left without "sufficient
time for an independent investigation that might surface evidence that refutes, mitigates, or
places the other act in a different light," and the Court will not have sufficient "time to consider
5
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the admissibility of the other act evidence." Wright & Miller, supra. Should the Government
request a "good-cause" exemption for their failure to timely provide Rule 404(b) notice, this
Court should analyze their excuse with skepticism. "Prosecutors should be prepared to explain
their change of heart and to rebut allegations of sandbagging. Unforeseen turns of testimony at
trial are one thing. Reasonably anticipated proof problems are another. For example, when intent
is an element of a charged offense, a prosecutor will be hard pressed to explain why he did not
foresee before trial that the other act proof may be important in a jury's determination of intent."
Wright & Miller, supra. Here, the government has been on notice of the elements it needs to
prove since July 2020. It advised the Court it would be able to provide Rule 404(b) notice back
in May 2021. Dkt. 229 at 3. With the trial continuance, it gained an additional five months. See
Dkt. 297.
There is no acceptable excuse for failure to follow the requirements of the Rule. Given
the significant number of other pre-trial filing deadlines, briefing the admissibility of the
proffered Rule 404(b) evidence in the midst of her other obligations will be exceptionally
difficult. If the Court is inclined to grant the government additional time to satisfy the Rule, Ms.
Maxwell requests ample time to investigate the materials and to respond.
III. Ms. Maxwell Needs Additional Time to Respond to the Scant Notice that the
Materials Qualify as "Direct Evidence" in the Case
The Rule 404(b) Letter also repeated the Government's opinion that the newly-disclosed
materials qualify as "direct evidence" of the conspiracy. At first blush, it is hard to see how they
could so qualify. The emails referenced in the Letter purport to be between Ms. Maxwell and
two adult men, apparently arranging dates for them, with adult women, sometime in the early
2000s. They do not reference or have anything to do with (a) the persons mentioned in the
Indictment or any other testifying witness, nor (b) any of the legal allegations contained in the
6
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=== Page 10 ===
Indictment. It is hard to imagine how an adult women fixing up single adult males with adult
females is "direct evidence" of a conspiracy to transport, entice or traffic minors for sexual
abuse.
As to the witness referenced in the Letter, the Letter makes clear that the witness worked
for Mr. Epstein from 2005-06, after the conclusion of the charged conspiracy in 2004. Given the
timing of her stated employment, it also begs the question how her testimony, reference to
unspecified documents or scheduling of unspecified massages, "among other things," could be
direct evidence of a conspiracy that ended a year earlier.
But because Ms. Maxwell has had insufficient time to investigate these newly-disclosed
materials, she is unable to file a motion challenging their admissibility at this time. The emails
involve two persons not interviewed by the Government, so there is no interview memo to
corroborate their content. At least two of the potential witnesses are foreign nationals who live
abroad. Ms. Maxwell will need time to contact and interview them. As to the newly disclosed
witness, the Government produced on October 12, 2021 approximately 400 pages of interview
reports, notes, documents, and other materials related to that witness. Ms. Maxwell is unable to
review, investigate, or rebut the admissibility of all of the referenced materials by the October
18, 2021 due date for motions in limine, and requests an additional two weeks to file her brief
addressing the proffered 404(b) evidence.
CONCLUSION
The Government has been on notice of the amendments to Rule 404(b) since at least
January 25, 2021. See Dkt. 146 at 10.¹ The Government was prepared to disclose their Rule
1 Indeed, the Government argued in their response to Ms. Maxwell's pretrial motions that certain evidence
pertaining to Accuser-3 would be admissible under Rule 404(b); yet the deadline to provide Notice of an
intent to offer that evidence at trial under the rule has come and gone. See Dkt. 204 at 165-169. Ms.
Maxwell today moves separately to exclude the evidence pertaining to Accuser-3.
7
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=== Page 11 ===
404(b) Notice by May 28, a date that was extended to October 11 after the continuance of the
trial. Dkt. 229 at 3. The failure to comply with the requirements of the Rule has deprived Ms.
Maxwell of the opportunity to litigate the issues on the timetable set by the Court. There is thus
no "good cause" for extending the Government's ability to do so. This Court should exclude any
evidence the government seeks belatedly to offer pursuant to Rule 404(b), or, alternatively
should the Court find good cause for the failure of notice, grant Ms. Maxwell additional time to
respond. As far as admissibility of the evidence referenced in the Letter as "direct evidence" of
the charged crimes, Ms. Maxwell seeks leave to file such a Motion within two weeks.
Dated: October 18, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Denver, CO 80203
Phone:
Christian R. Everdell
COHEN & GRESSER LLP
York, NY 10022
Phone:
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Phone:
Attorneys for Ghislaine Maxwell
8
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=== Page 12 ===
Certificate of Service
I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine
Maxwell's Motion to Exclude Any Evidence Offered by the Government Pursuant to Fed. R.
Evid. 404(b) for Failure to Comply with the Rule's Notice Requirement with the Clerk of Court
using the CM/ECF system which will send notification of such filing to the following:
U.S. Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
s/ Nicole Simmons
9
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=== Page 1 ===
From:
To:
Subject: Emails/Notes RE testifying
Date: Wed, 01 Dec 2021 00:06:43 +0000
Attachments: Redacted_text.pdf; Emails.zip; REDACTED_set_1.pdf
Hey
are the emails, one text i found and the set of emails my supervisor redacted. I have another set of notes my
supervisor redacted I may just have to print and bring with me for prep.
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=== Page 1 ===
From:
)"
To: Christian Everdell
Jeff Pagliuca
>, , Laura Menninger
Cc:
)"
)"
)"
Subject: Today's filings
Date: Mon, 22 Nov 2021 16:53:49 +0000
Attachments: 2021.11.20_Letter_to_Judge_Nathan_re_Birth_Certificates_[proposed_redactions].PDF;
2021-11-20_GM_reply_re_GX-52_final_[proposed_redactions]pdf;
2021.11.15_JSP_Ltr_re._EX._52_[proposed_redactions].pdf;
2021.11.18_Mot_to_admit_birth_certificates_[proposed_redactions].pdf
Counsel,
Today, we are supposed to docket redacted versions of (1) the briefing on birth certificates, (2) the remaining briefing on
GX-52, and (3) the Government's motion to quash. See Dkt. Nos. 473, 474, and 476.
Attached are our proposed redactions. We have no redactions to our motion to quash. Our understanding is that the
defense is not proposing any redactions.
We propose that we will file a cover letter on the docket and send these all to the Court. After that, we'll file the redacted
versions of our motions and you can file your responses, and we'll wait for you to file your redacted GX-52 brief before we
file our reply.
Please let us know if that works for you.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
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=== Page 1 ===
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
U.S. ATTORNEY GEOFFREY S. BERMAN
FOR IMMEDIATE RELEASE
CONTACT: U.S. ATTORNEY'S OFFICE
Monday, July 8, 2019
NYPD
FBI
Phil Walzak
JEFFREY EPSTEIN CHARGED IN MANHATTAN FEDERAL COURT
WITH SEX TRAFFICKING OF MINORS
Alleged Conduct Occurred in both New York and Florida over Multiple Years,
Involving Dozens of Victims
Geoffrey S. Berman, the United States Attorney for the Southern District of New York,
, the Assistant Director in Charge of the New York Field Office of the
Federal Bureau of Investigation ("FBI"), and
Commissioner of the New York
,
City Police Department ("NYPD"), announced that JEFFREY EPSTEIN was arrested Saturday
and charged with sex trafficking of minors and conspiracy to commit sex trafficking of minors.
The indictment unsealed today alleges that, between 2002 through 2005, EPSTEIN sexually
exploited and abused dozens of underage girls by enticing them to engage in sex acts with him in
exchange for money. Epstein allegedly worked with several employees and associates to ensure
that he had a steady supply of minor victims to abuse, and paid several of those victims
themselves to recruit other underage girls to engage in similar sex acts for money. He committed
these offenses in locations including New York, New York, and Palm Beach, Florida. EPSTEIN
is expected to be presented in Manhattan federal court this afternoon before U.S. Magistrate
Judge Henry B. Pitman. The case is assigned to U.S. District Judge Richard M. Berman.
U.S. Attorney Geoffrey S. Berman said: "As alleged, Jeffrey Epstein abused underage
girls for years, operating a scheme in which girls he victimized would recruit others for Epstein
to exploit and abuse. Epstein exploited girls who were vulnerable to abuse, enticed them with
cash payments, and escalated his conduct to include sex acts, often occurring at his residence on
the Upper East Side of Manhattan. While the charged conduct is from a number of years ago,
the victims - then children and now young women - are no less entitled to their day in court.
My Office is proud to stand up for these victims by bringing this indictment."
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=== Page 2 ===
FBI Assistant Director
said: "We are asking anyone who may
have been victimized by Jeffery Epstein, or anyone who may have information about his alleged
criminal behavior, to please call us. The number is 1-800-CALL-FBI. We want to hear from
you, regardless of the age you are now, or whatever age you were then, no matter the incident
that took place. The bravery it takes to call us might empower others to speak out about the
crimes committed against them. It is important to remember there was never, nor will there ever
be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come
first."
NYPD Commissioner
said: "Today's charges serve as a warning to
individuals who continue to prey upon some of our society's most vulnerable population: we are
coming for you. I thank and commend the U.S. Attorney's Office for the Southern District and
the FBI for their tireless efforts to ensure child predators are taken off our streets. The NYPD
will continue to work with our law enforcement partners to eradicate the trafficking of children
in our city and nation and work to bring justice to victims of these heinous crimes."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein,
please contact the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 2002 through at least 2005, JEFFREY EPSTEIN enticed and recruited, and
caused to be enticed and recruited, dozens of minor girls to visit his mansion in New York, New
York (the "New York Residence"), and his estate in Palm Beach, Florida (the "Palm Beach
Residence"), to engage in sex acts with him, after which he would give the victims hundreds of
dollars in cash. In order to maintain and increase his supply of victims, EPSTEIN also paid
certain victims to recruit additional underage girls whom he could similarly abuse. In this way,
EPSTEIN created a vast network of underage victims for him to sexually exploit, often on a
daily basis, in locations including New York and Palm Beach.
EPSTEIN's victims were as young as 14 at the time he abused them, and were, for
various reasons, often particularly vulnerable to exploitation. Moreover, EPSTEIN knew that
many of his victims were under 18, including because, in some instances, victims expressly told
him they were underage.
In creating and maintaining this network of minor victims in multiple states to abuse and
exploit sexually, EPSTEIN worked with others, including employees and associates who
facilitated his conduct by, among other things, contacting victims and scheduling their sexual
encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.
In both New York and Florida, EPSTEIN perpetuated this abuse in similar ways.
Victims were initially recruited to provide "massages" to EPSTEIN, which became increasingly
sexual in nature and would typically include one or more sex acts. EPSTEIN paid his victims
hundreds of dollars in cash for each encounter.
1
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment
set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation.
EFTA00014639

=== Page 3 ===
In particular, during encounters at the New York Residence, victims would be taken to a
room where they would perform a massage on EPSTEIN, during which EPSTEIN would
frequently escalate the nature and scope of physical contact with his victims to include, among
other things, sex acts such as groping and direct and indirect contact with the victims' genitals.
In connection with the encounters, EPSTEIN, or one of his employees or associates, typically
paid each victim hundreds of dollars in cash. Once minor victims were recruited, EPSTEIN or
his employees or associates would contact victims to schedule appointments for "massages." As
a result, many victims were abused by EPSTEIN on multiple subsequent occasions.
To further enable him to abuse underage girls, EPSTEIN asked and enticed certain of his
victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts
with EPSTEIN. When a victim would recruit another underage girl for EPSTEIN, he paid both
the victim-recruiter and the new victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN maintained a steady supply of new victims to exploit, and gained access to
dozens of additional underage girls to abuse.
JEFFREY EPSTEIN, 66, is charged with one count of sex trafficking of minors, which
carries a maximum sentence of 40 years in prison, and one count of conspiracy to engage in sex
trafficking of minors, which carries a maximum sentence of five years in prison.
The statutory maximum and mandatory penalties are prescribed by Congress and are
provided here for informational purposes only, as any sentencing of the defendant would be
determined by the judge.
Mr. Berman praised the outstanding investigative work of the FBI and the NYPD. He
also thanked the U.S. Customs and Border Protection for their assistance.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
Attorneys
are in charge of the prosecution,
with assistance from the Office's Human Trafficking Co-Coordinator,
The charges contained in the Indictment are merely accusations. The defendant is
presumed innocent unless and until proven guilty.
19-XXX
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=== Page 1 ===
From: Jeffery Edwards <jeevacation@gmail.com>
Date: 3 September 2008 at 10:48:50 GMT-7
To:
Subject: Re: i hear you've had a spot of bother
guess
On 9/3/08 1:06 PM,
wrote:
Ok will send pics later today or tomorrow. Anything in mind
?
Sent via BlackBerry by AT&T
From: Jeffery Edwards <jeevacation@gmail.com>
Date: Wed, 03 Sep 2008 12:19:06 -0400
To:
Subject: Re: i hear you've had a spot of bother
Making the best,, send photos please
EFTA00015078

=== Page 2 ===
On 9/2/08 8:41 PM,
wrote:
So how are you ?
Sent via BlackBerry by AT&T
From: Jeffery Edwards
<jeevacation@gmail.com>
Date: Tue, 02 Sep 2008 19:27:29 -0400
To:
Subject: Re: i hear you've had a spot of
bother
Tell
I appreciate the advice, but that
would be contraband, and the punishment
would be vaseline
On 9/2/08 6:56 PM,
wrote:
Well I suppose I will not be seeing
you while I am in New York to
my great disappointment.
How are you? I suppose you
are making the most of the
opportunity to read and observe
human behavior under duress and
confinement ! If there is anyone
who would maximize on such a
"vacation" it's you !
I am with
and he
is asking if you would like him to
send you some Vaseline !
Seriously though sweetheart, If I
can do anything let me know. I
hope you are keeping a diary
and I am sure you are keeping
fit !
EFTA00015079

=== Page 3 ===
Anyway,
best love always
XXXXX
P.S.If you would like me to come
and visit sometime it would be my
pleasure
EFTA00015080


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=== Page 1 ===
From:
To:
Cc:
)"
Subject: RE: travel approval request
Date: Wed, 12 Jun 2019 19:27:43 +0000
Importance: Normal
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
EFTA00014288

=== Page 2 ===
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
)
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00014289


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 501-1 Filed 11/24/21 Page 1 of 2
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
DATE FILED: 11/24/21
X
:
:
UNITED STATES OF AMERICA
[PROPOSED]
:
PROTECTIVE ORDER
:
- V. -
:
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
ALISON J. NATHAN, United States District Judge:
WHEREAS the Court has ordered production of materials
from the Epstein Victims' Compensation Fund to the Court
pursuant to Fed. R. Crim. P. 17 (c) (the "Rule 17 Materials")
(see Dkt. No. 496) ;
WHEREAS those materials are likely to contain
information that would (i) affect the privacy and
confidentiality of individuals, (ii) would risk prejudicial
pretrial publicity if publicly disseminated, and (iii) are not
authorized to be disclosed to the public or disclosed beyond
that which is necessary for the trial in this action;
WHEREAS the Court has directed the parties to
negotiate and submit a proposed protective order;
IT HEREBY IS ORDERED:
1.
Any and all Rule 17 Materials disclosed to the
Government, the defendant ("Defendant"), and/or to the
defendant's criminal defense attorneys ("Defense Counsel," and
1
EFTA00016485

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 501-1 Filed 11/24/21 Page 2 of 2
collectively with the Government, "the Parties") shall be
treated as "Confidential Information" within the meaning of the
Protective Order (Dkt. No. 36 I 7) and shall be subject to the
provisions thereof.
2. At the discretion of the Court, the Court may
designate certain materials as "Highly Confidential" within the
meaning of the Protective Order (Dkt. No. 36 I 11) and subject
to the provisions thereof.
SO ORDERED:
Dated:
New York, New York
November 24, 2021
Alim D.Netto
HONORABLE ALISON J. NATHAN
United States District Judge
2
EFTA00016486


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=== Page 1 ===
<
App Store
LTE
8:17 PM
,
ghislainemaxwell6
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0
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Posts
Followers
Following
Ghislainemaxwell
Follow
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When ghislainemaxwell6 posts, you'll see their
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EFTA00016322


c1: EFTA00014477
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c3: VOL00008
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Reporter question on Jeffrey Epstein
Date: Tue, 16 Jul 2019 16:43:46 +0000
Importance: Normal
Inline-Images: image001.png
FYI - we'll decline on this. Doubtful there's guidance, but let me now if you have any. Thanks.
From:
Sent: Tuesday, July 16, 2019 12:11 PM
To:
Subject: Reporter question on Jeffrey Epstein
Hi
Hope you're doing well! I'm a reporter with The Daily Beast and have been covering Jeffrey Epstein.
Today, attorneys for Mr. Epstein's victims said Mr. Epstein sexually abused a young woman while he was out on work
release in 2008-09.
Here is our story. Would love to get your insight: https://www.thedailybeast.com/jeffrey-epstein-abused-victims-while
serving-time-in-florida-lawyer-brad-edwards-says
Would you be able to comment on this? Did SDNY hear any complaints about Mr. Epstein's activities while on work
release? Could this perhaps factor into the case-especially as Mr. Epstein's legal team is trying to get him out on bail?
Alternately, could you provide any comment on background?
Please drop me a line or give me a call. My cell is
Thanks so much!
Senior Reporter
DAILY BEAST
Join Beast Inside, our new membership program, to get more of the journalism you trust and love.
EFTA00014477


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=== Page 1 ===
From:
To:
Ce:
Subject: SDNY Homepage
Date: Tue, 16 Jul 2019 18:32:58 +0000
Importance: Normal
Attachments: Epstein_Homepage.png
Inline-Images: image001.png
How would you guys feel about linking the victim/witness page to the attached image? It would replace the one pictured below.
Search
THE UNITED STATES ATTORNEY'S OFFICE
SOUTHERN DISTRICT of NEW YORK
SEARCH
HOME
ABOUT
DIVISIONS
RESOURCES
NEWS
PROGRAMS
EMPLOYMENT
CONTACT
SOCIAL MEDIA
f
Tweets by @SDNYnews
US Attorney SDNY
OF
@SDNYnews
Iranian national extradited and
charged, along with 2 others, with
exporting carbon fiber from the US
inb
to Iran go.usa.gov/xym5n
VEO
ENITED
DEPARTMENT
JUSTITIA
Manhattan U.
STATES
justice.gov
Public Service Announcement
on Sexual Assault in Public
24m
Housing
1
2
3
4
5
6
7
=
US Attorney SDNY
@SDNYnews
JUSTICE 101
Welcome to the U.S. Attorney's Office for the Southern District of
USA Berman: Polluters will be held
New York, which encompasses the boroughs of Manhattan and the
to account, even in bankruptcy, for
Bronx in New York City, along with Dutchess, Orange, Putnam,
contaminating the environment
Rockland, Sullivan, and Westchester counties. The Office prosecutes
cases involving violations of federal laws, and represents the interests
20h
of the United States government and its agencies in criminal and civil
matters. The Office investigates and prosecutes a broad array of
criminal conduct of every conceivable magnitude, even when the
NEWS
Community Outreach
conduct arises in distant places. Today, the Office is at the forefront of
many important areas of criminal law enforcement, including
July 16, 2019
Giving back to the community
terrorism, white collar and cyber crime, mortgage fraud, public
Manhattan U.S. Attorney
through a variety of venues &
corruption. gang violence. organized crime. international narcotics
Announces Extradition Of
initiatives.
Public Affairs
United States Department of Justice
U.S. Attorney's Office |Southern District of New York
EFTA00016743


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS) 6"
Subject: RE: call W SEC
Date: Thu, 08 Aug 2019 18:15:31 +0000
Ok. I'll aim for 4:45.
From:
(USANYS)
Sent: Thursday, August 8, 2019 2:04 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS) 6
Subject: RE: call W SEC
I think one or both of us free for the next hour or so, and then again after about 4:30.
From:
(USANYS)
Sent: Thursday, August 8, 2019 1:55 PM
To:
(USANYS)
i
(USANYS)
Cc:
(USANYS) 6
Subject: call W SEC
PCers,
SEC called again with some questions on their Epstein inquiry. They mainly want to continue to avoid anything that would
be problematic for the criminal case. We thought it would be easiest if some group of the 4 of us got on a call with them.
Do one or both of you have some availability this afternoon?
Thanks,
EFTA00015656


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=== Page 1 ===
MARCH 3, 2020
OPEN LETTER TO WILLIAM BARR -ATTORNEY GENERAL OF THE UNITED STATES
RE: Crimes Against Humanity taking place against America's seniors under the guise of
guardianship, a state of Florida sponsored organized crime racket.
Why isn't the Department of Justice "keeping our seniors safe?"
We are here at great effort and financial hardship to shed light on a government and State of
Florida sponsored guardian racket. Competent seniors and vulnerable adults with financial assets
are fraudulently being ruled incompetent by state paid actors in collusion with probate judges,
attorneys and guardians who ambush these vulnerable adults in their home on the basis of 5
minute encounters, without physical or medical evaluation. These vulnerable adults are then
forced into guardianship where they are illegally stripped of their civil rights by judges, attorneys
and guardians so they can't protect themselves and fight back and then these probate court corrupt
judges attorneys and guardians seize and steal their estates, their home, car, life savings,
investments, personal property, retirement accounts, social security, pension, art, jewelry and
family heirlooms. After all of their assets are stolen, they put these adults on a toxic medication
such as seroquel to cause their death by sudden cardiac arrest.
This is a billion dollar racket that enriches a relatively small group of judges, attorneys and
guardians and deprives the United States of the spending power of millions of American families
whose assets are embezzled in this criminal enterprise. This tramples any concept of "making
America great again."
The so called "court proceeding" is really an organized crime racket run through the court. The
capturing of vulnerable adults in guardianship has been widely exposed in the media as a form of
human trafficking.
Why is the F.B.I. and the Department of Justice allowing this racketeering enterprise to operate
out of the courts?
You are making a presentation about marketing and other scams against seniors and completely
ignoring the REAL DANGER AND THREAT TO THESE VULNERABLE ADULTS by the
Florida sponsored guardian court racket.
Those of us in attendance have collectively and individually filed thousands of criminal
complaints with you personally and your predecessors. Thus your office, the Department of
Justice is well aware of this criminal racket. Ashley Moody, Ron DeSantis and former governors
and attorneys generals and the State of Florida are intimately aware of this racket as they sponsor,
financially support and cover up this racket through their many collusive agencies in the state of
Florida including the "Office of Professional Guardianship" and the law enforcement arm of the
state of Florida, the Florida Department of Law Enforcement. Moreover, when we futilely
attempt remedy by suing these guardian judges as we have no other remedy, instead of being
investigated by Ashley Moody, they are represented by none other than Ashley Moody's office.
1
EFTA00015687

=== Page 2 ===
So far from "keeping our seniors safe" the state of Florida and the federal government are
subjecting them to horrors.
The monumental corruption and infestation of this organized crime racket into every level of
government in the state of Florida is epitomized by the ghoulish finding of nine dead bodies in
urns in the office of a prolific human trafficker and serial killer who operates under the title of
"guardian". What is being done? NOTHING. Why? Because she is being purported investigate
by the collusive cover up arm of the state of the Florida, the FDLE. Why isn't the attorney
general of the Department of Justice investigating the serial murder of 9 vulnerable adults? She
has been left unleashed on the public after payment of an insulting miniscule $22,000 bail.
Moreover, these serial deaths are being portrayed by the state of Florida as the acts of a solo,
lowly "guardian" This serial killing is not the result of murder by a solo, lowly predator
guardian; the kingpins of this serial killing/ extortion/human trafficking racket are state of
Florida color of law judges. This organized crime racket is being run by a terror type
network of so called "guardian judges, attorney and guardians throughout the state of
Florida and is being covered up and protected by Florida's attorney general, governor and
law enforcement.
Those of us who are here, myself included are children of these vulnerable adults and we have
watched in horror as our parent and other loved ones are murdered by the probate court racket.
In response to our thousands of complaint, you have ignored our pleas to not only "keep our
seniors safe" but to keep our seniors alive and from being human trafficked, murdered and
embezzled. You have done nothing. That is tantamount to collusion.
The failure by the Department of Justice to keep our seniors safe is also a failure by the DOJ to
keep us, their family members safe. We, the family members who expose this crime are viciously
attacked, stalked, our lives and liberty threatened by the corrupt judges involved. We are
embroiled in ceaseless litigation orchestrated by these predator attorneys, judges and guardians,
our assets are seized in fabricated lawsuits orchestrated by these corrupt state actors in collusion
with corrupt judges in other courts who protect the racket. We are forced into bankruptcy where
our assets are illegal seized and garnished. Our homes are stolen in foreclosure proceedings. Our
liberty is threatened. We are illegally stripped of our first amendment rights to free speech by
illegal gag orders.
The business of human trafficking, embezzlement and murder for hire is a flourishing business in
the state of Florida. The state of Florida has a propensity for enabling and covering up all forms
of human trafficking rackets. Florida's hand slap to Jeffrey Epstein, a serial rapist and human
trafficker and the resulting cover up inferno been played out on a national stage.
We wonder - does the corrupt Florida government fear Florida's economic foundation will break
without this illegal human trafficking empire? This is the reality by breaking apart and
eradicating this racket, the government is opening the door to legitimate, productive business that
will "make America great again". The sponsoring of a human trafficking murder for hire does
not make America great again. It makes America a barbaric Nazi derived nation.
2
EFTA00015688

=== Page 3 ===
We are crime victims and whistleblowers. We demand protection by Federal law enforcement.
We have compiled documents that graphically detail the workings on this crime on a global level
and how it is carried out against individually our families.
We want answers and remedy. We want this criminal racket eradicated. We want Federal grand
juries on a state-wide basis. We want urgent massive criminal investigation and arrests.
So we ask you Mr. Barr, attorney general of the United States, what are you going to do to protect
us and our families and America's seniors and keep us safe? We want to meet with you after this
presentation and your confirmation to such a meeting.
-o/ Barbara Stone
_s/Robert Sarhan
_s/Lesa M. Martino
Barbara Stone
Robert Sarhan
_s/Eliot Bernstein
_s/Miriam Hernandez
_s/Skender Hoti
Eliot Bernstein
3
EFTA00015689


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell discovery production
Date: Fri, 18 Dec 2020 21:29:05 +0000
Attachments: 2020.12.18_MDC - Maxwell_MAIN.pdf; 2020.12.18_MDC - Maxwell_PASSWORD.pdf
Hi
Today we are sending via FedEx another CD containing a small corrected production of discovery to Maxwell. Attached
please find copies of the accompanying cover letters.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016792


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=== Page 1 ===
From:
To:
Subject: Accepted: Call/Meeting on Epstein
Date: Fri, 07 Dec 2018 02:52:44 +0000
Importance: Normal
Attachments: unnamed
EFTA00014301


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=== Page 1 ===
From: "Stoddart, Allison"
To:
Cc: "Sahni, Anjan"
>, "Schubert, Daniel"
Subject: [EXTERNAL] JPMorgan Chase Production
Date: Tue, 23 Nov 2021 23:29:43 +0000
Attachments: 2021-11-23_SDNY_Letter.pdf
All,
Attached is a letter on behalf of our client, JPMorgan Chase, for a production that is being sent via FTP. The password for
the production is:
Please let us know if you have any issues accessing the materials.
Thank you,
Allison
Allison Stoddart I WilmerHale
Please consider the environment before printing this email.
This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not
the intended recipient, please notify us immediately-by replying to this message or by sending an email to postmaster@wilmerhale.com-and destroy all
copies of this message and any attachments. Thank you.
For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
EFTA00014877


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: Re: travel approval request
Date: Wed, 19 Feb 2020 16:08:06 +0000
Thanks very much
Sent from my iPhone
On Feb 19, 2020, at 08:41,
wrote:
Good morning
Yes,
informed me that the documentation for the conference room was filled out and confirmed for your
meeting for today from 5:00pm - 8:00pm as specified.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, February 18, 2020 11:58 AM
To:
is
Cc:
is
Subject: RE: travel approval request
Wanted to follow up on this - please let us know? I can call them directly if that's necessary. Thanks!
From:
Sent: Monday, February 17, 2020 13:03
To:
is
Cc:
is
Subject: FW: travel approval request
Re: the below, I just got a bounce-back from
that she's out tomorrow. Is this something one of you might be
able to check and/or assist with? Or should I just do it myself tomorrow?
thanks,
From:
Sent: Monday, February 17, 2020 13:02
To:
EFTA00014405

=== Page 2 ===
Cc:
is
i
Subject: RE: travel approval request
Wanted to see if you had reserved a conference room for us, per the below from Thursday? I got a confirmation for the
hotel (attached) but it doesn't seem to say anything about a conference room. Could you please let us know either
way? And if not yet, could you please reserve that for us tomorrow (Tuesday) and let us know when it's finalized?
thank you!
From:
Sent: Thursday, February 13, 2020 13:26
To:
is
Cc:
is
Subject: RE: travel approval request
Apologies for the slight delay yesterday on this travel, we had a witness scheduling issue so the travel will be a day later
than originally anticipated. The city is Pensacola, Florida, and it will be me and
(rather than
and
).
if you could please book me on the following flights:
Feb. 19: Delta, LGA to PNS, 9:00 a.m. (arriving 12:49 p.m.)
Feb. 20: Delta, PNS to LGA, 4:06 p.m. (arriving 9:41 p.m.)
And the following hotel, for the night of Feb. 19:
-
Hilton Garden Inn (listed in E2 as "HGI PENSACOLA AIRPORT MEDICAL")
We will also need a conference room at the Hilton Garden Inn for February 19, starting at 5:00 p.m. for three hours (or
for the entire day, if that's the only way they'll do it).
Please let us know if any questions or issues, and thanks as always.
From:
Sent: Wednesday, February 12, 2020 09:02
To:
is
>;
i
Cc:
)
Subject: Re: travel approval request
Hi,
Which specific city will the hotel be in?
If
could push the travel authorizations thru to
& I today, that would be great.. As well as sending the
conference room payment request to
Remember to take the FL tax exempt form along with you.
EFTA00014406

=== Page 3 ===
Thanks
Sent from my iPhone
On Feb 12, 2020, at 6:43 AM,
wrote:
Approved
Sent from my iPad
On Feb 11, 2020, at 7:53 PM,
)
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618),
and I would like to please
request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19.
We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to
get a conference room on 2/19.
Thank you,
From:
Sent: Tuesday, January 21, 2020 2:56 PM
To:
Cc:
>;
is
is
is
Subject: RE: travel approval request
Approved
From:
Sent: Tuesday, January 21, 2020 2:49 PM
To:
Cc:
is
)
y
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the
27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on
our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of
those days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as
well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and
input on that.
thank you,
EFTA00014407

=== Page 4 ===
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior
trips, we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be
traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
is
is
(
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
EFTA00014408

=== Page 5 ===
thanks very much,
From:
)
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
>;
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel
next week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return
no later than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination
of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
>;
)
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to
fly down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
either be me and
or
and
but we wanted to ask for permission now either way so we weren't
doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
EFTA00014409

=== Page 6 ===
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors
for sexual activity,
and I would like to please request permission to travel for approximately three days next
week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down
Tuesday night and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00014410


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=== Page 1 ===
09
JPMorgan Chase Bank
2002
345 Park Avenue, New York, NY 10154-1002
JPMorgan Private Bank
Account Number: Q 79961-00-1
Asset Account Portfolio
Page 8 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Activity by Date
continued
Settlement
Date
Type
Quantity Description
Amount USD
Sep 16 Misc. Disbursement
TRANSFERRED BY WIRE TO
- 1,000,000.00
PALM BEACH NATL BK & TR CO
FAO JEFFREY EPSTEIN
LETTER FROM CLIENT
Sep 18 Sale
-5,000,000 JP MORGAN TAX FREE MONEY MARKET
5,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 09/18/02
Sep 18 Misc. Disbursement
TRANSFERRED BY WIRE TO
-5,000,000.00
PALM BEACH NATL BK & TR CO
FAO GHISLAINE MAXWELL
LETTER FROM CLIENT
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005512
Chase
EFTA00015183


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=== Page 1 ===
From:
To:
Subject: any of you have vouchers for Epstein victims.
Date: Thu, 14 Nov 2019 17:50:45 +0000
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
Tel.
EFTA00015941


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=== Page 1 ===
From: Jeffrey Epstein <jeevacation@gmail.com>
Date: 29 June 2010 at 00:51:08 GMT-7
To:
Subject: Re: where are u ?
for how long?
On Tue, Jun 29, 2010 at 3:25 AM,
wrote:
Your numbers dont work anymore call me
Coming to new york Sunday X
EFTA00015076

=== Page 2 ===
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
Jeffrey Epstein
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
return e-mail or by e-mail to jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00015077


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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
May 14, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The parties respectfully and jointly write to request an extension of time to file a letter in
response to the Court's Order of May 11, 2021, requiring the parties to submit a joint letter
regarding the overall pretrial schedule. (Dkt. No. 277). The joint letter is currently due on May
14, 2021, and the parties respectfully request an extension to May 21, 2021. No previous requests
for an extension of this deadline have been made.
EFTA00014636

=== Page 2 ===
Page 2
The parties seek this extension in order to permit continuation of productive discussions
that the parties have already initiated regarding the pretrial schedule. The parties conferred
yesterday for approximately 45 minutes by telephone on that topic. Although the conversation
was productive, there remain multiple points of disagreement. The requested extension will permit
the parties to consider each other's proposals as to certain deadlines, and to further confer with the
aim of minimizing the points of disagreement that will need to be resolved by the Court.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Cc: Defense counsel (By ECF)
EFTA00014637


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=== Page 1 ===
From: "Moyne, Parvin"
To:
)"
Cc: "DiPiero, Joseph"
"Moyer, Thomas"
)"
)"
Subject: RE: Epstein accounts
Date: Mon, 03 Aug 2020 16:12:20 +0000
I hope you are well and getting some time "off" this summer. I'm reaching out via email as it may be the most efficient
way to tee-up the inquiry we have received, but we can circulate a dial-in at a convenient time for you if you'd like to
discuss anything.
Deutsche Bank has received a third-party subpoena from the Attorney General's Office of the U.S. Virgin Islands in
connection with a pending civil suit they have filed against Jeffrey Epstein's estate, the executors of the estate, and
others. One of the requests is for a copy of any government subpoenas received by the Bank relating to Epstein, and a
copy of any productions made pursuant to the subpoenas. Do we have your permission to disclose your subpoena and
our production to you to the U.S.V.I. AG? Would you prefer us to refer the office to you directly or provide you with
contact information? I'm happy to send you a copy of the U.S.V.I. AG subpoena if helpful in evaluating the request.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
Direct:
Internal:
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.
EFTA00017084


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
,
)"
)"
>, ,
(NY) (FBI)"
(USANYS)"
i
,
(NY) (FBI)"
Subject: Fwd: SDNY Premises Search Warrant Bundle (second revised) copy
Date: Thu, 02 Jul 2020 12:17:50 +0000
Attachments: SDNY_Premises_Search_Varrant_Bundle_(second_revised)_copy.pdf,ATT00001.htm
Signed affidavit and warrant attached.
Begin forwarded message:
From:
"
(USANH)"
Date: July 2, 2020 at 8:14:23 AM EDT
To:
)"
(USANH)"
Subject: Fwd: SDNY Premises Search Warrant Bundle (second revised) copy
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 8:09:59 AM EDT
To:
i
(USANH)"
Subject: SDNY Premises Search Warrant Bundle (second revised) copy
EFTA00016163


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=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
HADDON
FX 303.832.2628
MORGAN
www.hmflaw.com
FOREMAN
jpagliuca@hmflaw.com
November 8, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Defendant's Good Faith, Non-Frivolous Objections to Proffered Co-Conspirator
Hearsay Statements
Dear Counsel,
Pursuant to the Court's November 1, 2021 Order we write to note our good faith
objections to certain categories of alleged co-conspirator hearsay statements, and representative
examples:
Regarding the first, third, and fourth¹ designated categories, there are two issues for
conferral. First, we assume that these proffered statements are limited to those individuals
specifically identified by the government as "minor victims" in the indictment or correspondence
to defense counsel dated October 11, 2021. There were many alleged minor victims in the
Southern Florida state and federal investigations. To the extent that the government intends to
include statements made to other alleged "minor victims" not specifically identified, Ms.
1
"Statements made by Epstein to friends and Family of Minor Victims," "Statements
made by CC-2 to friends and Family of Minor Victims," and "Statements made by Jeffrey
Epstein to the Minor Victims or in their presence."
EFTA00014982

=== Page 2 ===
November 8, 2021
Page 2
Maxwell objects. In addition, these categories do not contain any temporal limitations and we
object to any statements allegedly made outside the dates of the alleged conspiracy.
Category 2, "Statements made by Jeffrey Epstein to his employees" appears to, primarily,
relate to statements that post-date any alleged conspiracy. The first exemplar is a statement
allegedly from Epstein to CC-1 claiming that Ms. Maxwell "used to find girls for him." This
statement, or statements like it, cannot have been made either in the course of or in furtherance
of any conspiracy at issue here and are no more than "idle chatter." United States V. Lieberman,
637 F.2d 95, 102 (2d Cir. 1980) (challenged testimony "smack[ed] of nothing more than casual
conversation about past events. It is difficult to envision how it would have furthered the
conspiracy"). Similarly, the second example concerns direction from Epstein and CC-2 to CC-1
to "help someone who was coming to take the computers. " Again, this statement does not
appear to be during or in furtherance of any conspiracy alleged in the indictment. See Lutwak V.
United States, 344 U.S. 604 (1953); Krulewitch V. United States, 336 U.S. 440 (1949). We
assume the third example relates to the time period alleged in the indictment. To the extent it
does not we object.
Best Regards,
Jeffrey S. Pagliuca
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 269 Filed 05/04/21 Page 1 of 9
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
May 4, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in connection with the Court's Order of
April 27, 2021, regarding the defendant's request for an order authorizing a subpoena pursuant to
Rule 17(c)(3) of the Federal Rules of Criminal Procedure for records from Boies Schiller Flexner
LLP ("BSF"). In the Order, the Court directed the Government to notify the Court of its views as
to Requests 9 through 11. For the reasons set forth below, the Government respectfully submits
that Requests 9 and 11 should be denied, and the Court should reserve decision with respect to
Request 10, which the Government expects may be rendered moot.
I.
Applicable Law
As the Court explained in its Order, a defendant seeking material pursuant to a Rule 17(c)
subpoena bears the burden of satisfying the standard in United States V. Nixon, 418 U.S. 683
(1974). Pursuant to that standard, a Rule 17(c) subpoena "should not issue unless it meets three
criteria: '(1) relevancy, (2) admissibility, (3) specificity." United States V. Binday, 908 F. Supp.
2d 485, 491 (S.D.N.Y. 2012) (quoting Nixon, 418 U.S. at 700).
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Page 2
The Nixon test is enforced strictly. "The party requesting the subpoena must also show
that the information sought is 'not otherwise procurable reasonably in advance of trial by exercise
of due diligence,' that 'the party cannot properly prepare for trial without such production,' and
that 'the application is made in good faith and is not intended as a general "fishing expedition."
United States V. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (quoting Nixon, 418 U.S. at 699-700),
abrogated on other grounds as recognized by United States V. Chambers, 751 F. App'x 44, 46 &
n.1 (2d Cir. 2018) (summary order). It is not sufficient for a party to show only that the subpoenaed
documents "are potentially relevant or admissible." United States V. Wey, 252 F. Supp. 3d 237,
254 (S.D.N.Y. 2017) (internal quotation marks omitted). Moreover, as the Court has explained,
impeachment material is not "relevant" within the meaning of Nixon "until after the witness
testifies." (Order at 5). See Nixon, 418 U.S. at 701 ("[g]enerally, the need for evidence to impeach
witnesses is insufficient to require its production in advance of trial" (citations omitted)). Finally,
Rule 17 by its terms prohibits subpoenas aimed at statements "of a witness or a prospective
witness." See Fed. R. Crim. P. 17(h).
II.
Discussion
Although the Government has not seen the proposed subpoena, the Government
understands that Request 9 seeks the complete diary of Minor Victim-2, Request 10 seeks a pair
of boots given to Minor Victim-2, and Request 11 seeks a series of photographs. Requests 9 and
11 should be denied. The Government is working to moot Request 10, so the Court should reserve
decision on that request until it can be denied as moot.
A. Request 9
The Government understands that Request 9 calls for Minor Victim-2's entire diary from
her teenage years. This request is improper under Rule 17 in three respects.
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Page 3
First, the defendant has not adequately identified why the diary is relevant beyond the
portions of the diary the defense has already received. See Ulbricht, 858 F.3d at 109 (explaining
that Rule 17(c) is not appropriate for evidence that is "otherwise procurable" (internal quotation
marks omitted)). BSF represents that "all potentially relevant pages were produced from this
journal to the Defendant in civil discovery in another matter." (3/22/21 Letter from BSF, Dkt. No.
191 at 5). The Government also obtained and produced seven pages of the diary to the defendant
in discovery. (Mot. for a Bill of Particulars and Pretrial Disclosures, Dkt. No. 148 at 10).
The defendant argues that the entire diary is exculpatory because it contains no reference
to her. (4/2/21 Letter from Def., Dkt. No. 244 at 9). But the Government and Minor Victim-2
have acknowledged the absence of references to the defendant from the start, and Minor Victim-2
is expected to testify to that fact at trial. (See Gov't Omnibus Response, Dkt. No. 204 at 187 (citing
Mem. in Opp. to Def.'s Renewed Motion for Release, Dkt. No. 100 at 11 n.2.); 3/22/21 Letter from
BSF, Dkt. No. 191 at 5). The defendant earlier moved to compel the Government to obtain and
produce the diary to her, a motion the Court has denied. (Opinion & Order, Dkt. No. 207 at 29).
As the Government explained in its opposition to that motion, the Government understands that
Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no
entries regarding her later trip with Epstein, during which she met the defendant. (See Gov't
Omnibus Response, Dkt. No. 204 at 187). The victim provided the Government with her entries
relating to Epstein, which the Government in turn produced to the defense. (Id.). The remainder
of the diary consists of Minor Victim-2's unrelated personal diary entries, and the defendant has
not explained and cannot explain why she needs to review those entries to establish a fact that the
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Page 4
Government has acknowledged. In other words, there will be no dispute at trial that Minor Victim-
2 did not write about the defendant in her diary.¹
The cases the defendant cites are inapposite. For instance, in United States V. Cheung Kin
Ping, 555 F.2d 1069 (2d Cir. 1977), the parties learned that a cooperating witness kept a diary,
which was largely written in Chinese, while the witness was still on cross-examination. Id. at
1078. The witness turned over his diary, but after observing that the "defense was examining his
diary, he requested that this not be done." Id. While the parties were discussing how to review
the diary, including for Brady material, the diary was returned to the witness. It was only given to
the defense for examination after "roughly five days" in the witness's possession. Id. at 1079.
Accordingly, in that case, a diary that had never been evaluated for Brady material-or any other
material-was taken from a witness in the middle of the witness's cross-examination, then
returned to him for five days. The Second Circuit found that those events "created a serious risk
that significant material would be destroyed or tampered with." Id. Here, in contrast, the diary
contains no relevant material-in fact, that is the defendant's very thesis. See also White V.
McKinley, 519 F.3d 806, 814 (8th Cir. 2008) (explaining, in a $ 1983 case, that the plaintiff had
alleged bad faith by stating that a law enforcement officer in a child molestation case "deliberately
steer[ed] the investigation to benefit his love interest," in part by "fail[ing] to preserve the alleged
victim's diary which did not corroborate the molestation allegations," which in turn "deprived [the
defendant] of his right to a fair trial, in part, because he could not testify about the diary without
waiving his right not to testify"); United States V. Rios, No. 88 Cr. 186, 1989 WL 9289, at *2
1
For similar reasons, the entire diary, full of Minor Vicitm-2's personal and unrelated information,
would not be admissible at trial. See Nixon, 418 U.S. 700 (requiring that a Rule 17(c) subpoena
target "admissib[le]" evidence).
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Page 5
(N.D.N.Y. Feb. 6, 1989) (reaching the unremarkable result that an "undercover agent's diary" is
"not discoverable in and of itself" except "to the extent that this diary contains" Brady material).
Alternatively, the defendant states that she needs to inspect the "entire journal" to
"establish whether the journal is authentic and complete and whether or not spoilation has
occurred." (4/2/21 Letter from Def., Dkt. No. 244 at 9). "This examination," she continues,
"requires the services of a qualified forensic document examiner." (Id.) This argument lacks
merit. The defendant's bare assertion that authenticity might somehow be in doubt is hardly a
sufficiently detailed explanation of relevance and admissibility to justify a subpoena for a minor
victim's personal journal. The defendant does not identify any basis for doubting the authenticity
of the documents, which the Government expects that Minor Victim-2 will be able to properly
authenticate at trial. Nor does the defendant identify what kind of examiner she intends to use,
what kind of examination will occur, or how that examination might bear on the journal's
authenticity. See Wey, 252 F. Supp. 3d at 253 (explaining that the "items sought cannot merely be
potentially relevant or admissible. Rather, they must be shown to be relevant and admissible at
the time the subpoena is sought." (internal quotation marks omitted)); see also United States V.
Skelos, No. 15-CR-317 (KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018), aff'd 988
F.3d 645 (2d Cir. 2021) ("[A] criminal subpoena should not be used as 'a discovery device,' but
instead should be used only as 'a mechanism for obtaining specific admissible evidence." (quoting
United States V. Barnes, No. 04 Cr. 186 (SCR), 2008 WL 9359654, at *4 (S.D.N.Y. Apr. 2, 2008)).
"Conclusory statements," like the defendant's here, are "insufficient to satisfy the Nixon
requirements." Barnes, 2008 WL 9359654, at *3.2
2 In addition to the explicit bases identified in her letter on the subpoena and described above,
elsewhere the defendant has made clear that she seeks the diary for impeachment purposes. (See
Mot. for a Bill of Particulars and Pretrial Disclosures, Dkt. No. 148 at 10; 3/22/21 Letter from
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Second, the request in insufficiently specific. To satisfy the specificity prong, a Rule 17(c)
subpoena must be able to "reasonably specify the information contained or believed to be
contained in the documents sought rather than merely hop[e] that something useful will turn up."
Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g.,
United States V. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 508682, at *4 (S.D.N.Y. Jan. 31, 2020).
The defendant's request for the entire diary is likely to sweep in a significant period of Minor
Victim-2's life before Minor Victim-2 met Epstein or the defendant-all of which is irrelevant.
To justify this overbreadth, the defendant identifies two reasons she needs to review the
diary in full: to demonstrate the absence of references to the defendant, and to establish the diary's
authenticity. (4/2/21 Letter from Def., Dkt. No. 244 at 9). As to the former, there is no probative
value in showing that diary entries before the defendant had ever met Epstein or the defendant
contain no references to Epstein or the defendant, and in any event, the Government has conceded
the point. As to the latter, the defendant offers only the conclusory statement that review of the
entire diary is necessary. That is insufficient, as explained above.
Third, the request is barred by Rule 17(h). That section prohibits the use of Rule 17 to
"subpoena a statement of a witness or of a prospective witness," Fed. R. Crim. P. 17(h), explaining
that such issues are governed by Rule 26.2. The diary is a set of recorded statements by Minor
Victim-2. To the extent it should be produced, that production is governed by Rule 16, Rule 26.2,
Brady, and Giglio, but not Rule 17. See, e.g., United States V. Carton, 17 Cr. 680 (CM), 2018 WL
5818107, at *4 (S.D.N.Y. Oct. 19, 2018) (rejecting a request for a personnel file because the
BSF, Dkt. No. 191 at 5 ("The Defendant also clearly seeks to use the journal for impeachment
purposes, as highlighted in a prior filing in a recently dismissed civil action Ms. Farmer filed
against the Defendant.")). But as the Court has recently explained, Rule 17 is not a tool to obtain
impeachment material in advance of trial. (Order at 5).
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individual "is a prospective witness in this case; the Government will provide Carton with his
3500, Jencks and Giglio material by the deadline set by the Court"); United States V. Yudong Zhu,
No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a
subpoena request under Rule 17(h) even though the records were not in the Government's
possession). Here, the Government has discharged its obligations already by providing the
defendant with the relevant pages from the diary, and Rule 17(h) bars a search for additional
statements.
The defendant's theories miss the mark because Request 9, at its core, is precisely the sort
of "fishing expedition" that Nixon prohibits. 418 U.S. at 700. Accordingly, Request 9 should be
denied.
B. Request 10
The Government understands Request 10 to seek a pair of boots purchased by the defendant
and Jeffrey Epstein for Minor Victim-2. The defendant states that she would like to examine the
boots in order to "identify the make and provenance of the boots." (4/2/21 Letter from Def., Dkt.
No. 244 at 11). This appears to be an attempt to use the boots to impeach Minor Victim-2's
testimony, shrouded again in a conclusory claim about the need for authentication. For
substantially the reasons set forth above with respect to the diary, the Government respectfully
submits such a claim is meritless under Nixon.
However, and although the Government is not obligated to do so, the Government has
requested that BSF provide the boots to the Federal Bureau of Investigation ("FBI"). BSF has
indicated that Minor Victim-2 will likely agree to do so. When the boots are in the FBI's custody,
the Government intends to make them available promptly to the defense for examination and use
at trial, and will so notify the Court, which should moot Request 10. The Government submits,
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Page 8
thus, that the Court need not resolve Request 10 at this time, as the Court will likely be able to
deny it as moot in the near term.
C. Request 11
Request 11 appears to seek a series of photographs. The Government's understanding is
that the defendant already has copies of those photographs. (See 4/2/21 Letter from Def., Dkt. No.
244 at 11 ("[C]opies were produced by BSF in civil litigation.")). It also appears that the
Government also produced copies of some of these photographs in Rule 16 discovery. In any
event, and again although the Government is not obligated to do so, the Government requested
that BSF provide it with copies of the complete set of requested photographs, which it has obtained
and produced to the defendant.
Remaining at issue, then, are only the original versions of the photographs. The
Government understands from BSF that the photographs were all taken on film and are not digital
photographs. Accordingly, the originals are physical photographs, not digital files. The defense
subpoena for these original photographs should be denied, at least unless and until the defendant
provides further justification for the need for and entitlement to the originals. Because the
defendant already has copies of the photographs, the defendant must explain how her request for
the originals can satisfy the Nixon test without being "otherwise procurable." 418 U.S. at 699.
The defendant suggests that she needs the originals to identify the "dates of creation or any
other specifics." (4/2/21 Letter from Def., Dkt. No. 244 at 11). It is entirely unclear what "other
specifics" refers to, but as noted above, the Government understands that these photographs were
taken on film, such that the originals would generally not contain metadata regarding the date or
other information regarding when they were taken. And in any event, the defendant has not
explained the relevance or admissibility of this information-and specifically, whether it would
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Page 9
be used for impeachment, authentication, or another purpose. Accordingly, Request 11 should be
denied.
III.
Conclusion
For the foregoing reasons, the Court should deny Requests 9 and 11. The Court should
reserve decision with respect to Request 10 until the Government obtains the boots and makes
them available for inspection by the defendant, at which time Request 10 will be moot.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
by:
/s/
Assistant United States Attorneys
cc:
Counsel of Record (by ECF)
EFTA00015873


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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 1 of 34
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
V.
20-CV-00833 (PAE)
FEDERAL BUREAU OF PRISONS,
Defendant.
DECLARATION OF KARA CHRISTENSON
I, Kara Christenson, declare as follows:
1. I am employed by the United States Department of Justice, Federal Bureau of Prisons
("BOP"), as a Government Information Specialist ("GIS") for Central Office, stationed at the
Federal Medical Center in Rochester, Minnesota ("FMC Rochester"). I have been assigned to
Central Office since August 2016. Prior to that time, I served as a Paralegal for the North Central
Regional Office ("NCRO") from September 2008 to August 2016. From June of 1994 through
September of 2008, I served in various legal support positions for the Legal Department at the
Federal Medical Center (FMC) in Rochester, MN. I have been employed by the BOP since March
1992.
2. As a Government Information Specialist, my duties include serving as a Freedom of
Information Act (FOIA) Specialist responsible for all facets of processing FOIA and Privacy Act
(PA) requests, with primary responsibility for analysis of, responses to, and monitoring of requests
for BOP records pursuant to 5 U.S.C. § 552. I also provide litigation support for the FOIA
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 2 of 34
requests assigned to me. In addition to these responsibilities, I am authorized to review for final
BOP disposition the FOIA determination responses prepared by other GIS staff in my office.
3.
I submit this declaration in support of the BOP's motion for summary judgment, to
describe BOP's search for records responsive to the FOIA requests submitted by Plaintiff, review
of responsive records, and application of exemptions to responsive records.
4.
The statements made in this declaration are based upon my personal knowledge
and information available to me in my official capacity and about which I have become
knowledgeable.
I.
PLAINTIFF'S FOIA REQUESTS
A.
FOIA Request 2019-05665
5.
In an email dated August 13, 2019, the BOP received a FOIA request from Plaintiff.
The FOIA request sought documents "about Jeffrey Epstein who died at the Metropolitan
Correctional Center (MCC) on Aug. 10, 2019." See Attachment 1, Plaintiff's FOIA request dated
August 13, 2019. Specifically, Plaintiff sought the following records:
(1)
The signed log in the Special Housing Unit at MCC that shows
when prison staff did rounds on July 22 and 23, and Aug. 9 and 10;
(2)
All quarter entries (showing which cells he was housed in) for
Jeffrey Epstein at MCC;
(3)
The CIM Clearance and Separatee data sheet for Jeffrey Epstein at
MCC;
(4)
The chronological disciplinary records for Jeffrey Epstein at MCC;
(5)
The intake screening form for Jeffrey Epstein at MCC;
(6)
The security designation records for Jeffrey Epstein at MCC;
(7)
The inmate profile for Jeffrey Epstein at MCC;
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(8)
All incident reports related to Jeffrey Epstein at MCC;
(9)
All medical reports related to Jeffrey Epstein at MCC;
(10)
The signed visitor log for Jeffrey Epstein at MCC;
(11)
Documents showing when MCC staff held meetings regarding
Jeffrey Epstein, and who attended;
(12)
All records generated from the meeting at MCC during which it
was decided that Jeffrey Epstein would be taken off suicide watch;
(13)
The Post-Watch report compiled in order to take Jeffrey Epstein
off suicide watch;
(14)
The overtime sign-up sheets for the Special Housing Unit (9
South) at MCC for Aug. 9 and 10, and on July 22 and 23; and
(15)
Documents showing which staff were augmented at MCC and
what positions they worked in on Aug. 9 and 10, and on July 22
and 23.
See id.
6.
In a separate email, also dated August 13, 2019, the BOP received a second
FOIA request from Plaintiff for documents "about Jeffrey Epstein who died at the
Metropolitan Correctional Center (MCC) on Aug. 10, 2019." See Attachment 2,
Plaintiff's FOIA request dated August 13, 2019, Email 2. Specifically, Plaintiff sought
the following records:
(1)
All video camera footage at MCC pertinent to the Jeffrey Epstein
suicide and the first suicide attempt;
(2)
All BOP documents pertaining to Jeffrey Epstein's suicide and first
suicide attempt;
(3)
All BOP documents, including email correspondence and meeting
minutes, pertaining to the decision to remove Jeffrey Epstein from
suicide watch;
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(4)
All BOP special investigation reports mentioning Jeffrey Epstein;
and
(5)
All BOP correspondence with the U.S. Attorney's Office regarding
Jeffrey Epstein.
See id.
7.
Because these two email requests from the Plaintiff were dated the same date and
received by the BOP on the same date, the BOP consolidated the requests as one request and
assigned this consolidated request FOIA Request Number 2019-05665. On September 23, 2019,
the BOP issued its final determination response regarding FOIA Request 2019-05665. See
Attachment 3, Determination Response for FOIA Request 2019-05665. In its final determination
response, the BOP categorically denied the request because "any records responsive to your
request are categorically exempt from disclosure pursuant to the Freedom of Information Act, 5
U.S.C. §§ 552 (b)(5); (b)(6); (b)(7)(A); (b)(7)(C); (b)(7)(E); and (b)(7)(F). Id. The BOP also
advised Plaintiff, as to exemption (b)(7)(A), the application of the exemption was temporarily
utilized "to protect active and on-going law enforcement proceedings." Id.
8.
Plaintiff appealed the BOP's determination response to the Office of Information
Policy ("OIP"), and in response, OIP affirmed the BOP's determination response on partially
modified grounds. See Attachment 4, OIP Determination Response on Plaintiff's Appeal.
Specifically, OIP determined the "BOP properly withheld this information in full because it is
protected from disclosure under the FOIA pursuant to 5 U.S.C. § 552(b)(7)(A) and it is reasonably
foreseeable that disclosure of this information would harm the interests protected by this
provision." Id. OIP did not adjudicate the applicability of the other exemptions asserted by the
BOP. Id.
B.
FOIA Request 2020-01336
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9.
In an email dated December 12, 2019, the BOP received a third FOIA request from
Plaintiff for documents "about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019." See Attachment 5, Plaintiff's FOIA request dated December 12, 2019.
Specifically, Plaintiff sought the following records:
(1)
The full log of Mr. Epstein's phone calls to and from the MCC;
(2)
All email correspondence to and from Mr. Epstein while he was at the MCC
(including any correspondence through the Corrlinks system or any other
email system he had access to);
(3)
The full log of people who visited Epstein while he was at the MCC when
they visited;
(4)
The full list of people that Mr. Epstein had requested to be on his
approved visitor list;
(5)
The full list of people that Mr. Epstein had requested to be on his
approved email correspondence list; and
(6)
The full list of people that Mr. Epstein had requested to be on his
approved call list.
See id.
10. In an email dated January 2, 2020, the BOP received a fourth FOIA request from
Plaintiff for documents "about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019." See Attachment 6, Plaintiff's FOIA request dated January 2, 2020.
Specifically, Plaintiff sought the following records:
(1)
The full recordings of the last three phone conversations that Mr. Epstein
had.
See id.
11.
In a response to the Plaintiff dated January 9, 2020, the BOP advised Plaintiff that
the January 2, 2020, request and the December 19, 2020, request were aggregated under FOIA
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Request Number 2020-01336. See Attachment 7, January 9, 2020, Aggregation of Requests
Response Letter. The BOP did not issue a final determination response concerning FOIA Request
2020-01336 prior to the filing of this action. On January 30, 2020, Plaintiff filed its Complaint in
this case.
II.
SEARCH FOR RECORDS
12.
The BOP initiated a search of its records systems to identify records and other
information potentially responsive to Plaintiff's FOIA requests. This search process entailed my
consulting with staff across BOP divisions, offices, and facilities regarding the various items
requested in Plaintiff's FOIA requests, and determining which BOP divisions, offices or facilities
likely maintained potentially responsive records; staff undertaking searches for records; and staff
subsequently forwarding any potentially responsive records to me for review to determine whether
the records were responsive to the request, whether any records were duplicates of any other
records received in response to the search; whether any records were exempt in whole or in part
pursuant to any FOIA exemption; and whether any non-exempt information could be reasonably
segregated from otherwise exempt records pursuant to FOIA to provide maximum release of the
records.
A.
BOP's Search for Records and Records Retrieved
13.
SHULOGS - Based the experience and training of myself and other staff involved
in searching for records, it was determined that the SHU at MCC New York is the most likely
place to locate records responsive to the request for "[t]he signed log in the Special Housing
Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 1."
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However, the SHU log books in question were handed over to the Office of the Inspector
General ("OIG") on or about August 22, 2019. Therefore, the BOP is no longer in possession
of the log books that are the subject of the FOIA request, and no responsive records were
located. Scanned copies of certain log book pages, count slips, or other records showing when
staff conducted rounds in the SHU were retained in the electronic files of certain individual
staff members at MCC and were located through their searches for these documents.
14.
SENTRY QUARTER'S HISTORY - Based on the experience and training of
myself and other staff involved in searching for records, it was determined that the SENTRY
database was the most likely place where records responsive to the request for "[a]ll quarter entries
(showing which cells he was housed in) for Jeffrey Epstein at MCC" would be located. The BOP
SENTRY database is a real-time information system consisting of various applications for
processing sensitive but unclassified (SBU) inmate information and for property management.
Data collected and stored in the system include information relating to the care, classification,
subsistence, protection, discipline, and programs of federal inmates. To search SENTRY for
responsive information, staff used Jeffrey Epstein's unique inmate register number of 76318-054
and the transaction code of PP37 for Quarters history. The search returned the Inmate History
Quarters for inmate Epstein, which was produced to Plaintiff on June 22, 2019, with redactions.
15.
CIM CLEARANCE SHEET/SEPARATEE DATA - Based on the experience
and training of myself and other staff involved in searching for records, it was determined that the
SENTRY database was the most likely place where the "CIM Clearance and Separatee data sheet
for Jeffrey Epstein at MCC" would be located. To search SENTRY for responsive information,
staff used Jeffrey Epstein's unique inmate register number of 76318-054 and the transaction code
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of PP10 for CIM and Separatee information. This SENTRY search returned the CIM Clearance
and Separatee data sheet for inmate Epstein, which was produced to Plaintiff in full on June 22,
2019.
16.
DISCIPLINARY RECORDS - Based on the experience and training of myself
and other staff involved in searching for records, it was determined that the SENTRY database
was the most likely place where the "chronological disciplinary records for Jeffrey Epstein at
MCC" would be located. To search SENTRY for responsive information, staff used Jeffrey
Epstein's unique inmate Register Number of 76318-054 and the transaction code of PD15 for
disciplinary history. This SENTRY search returned the disciplinary history for inmate Epstein
which was produced to Plaintiff in full on June 22, 2019, and one incident report for Epstein, which
was withheld in full as noted in the attached index at Entry 1.
17.
INTAKE SCREENING FORM - Based on the experience and training of myself
and other staff involved in searching for records, it was determined that the DROP File was where
records responsive to the request for "the intake screening form for Jeffrey Epstein at MCC" would
be located. A DROP File is a temporary, condensed version of a typical inmate Central File.
(Program Statement 5800.17, Inmate Central Files, Privacy Folder and Parole Mini-Files) Only
inmates in pre-trial status have their records maintained in a DROP File. Upon an inmate's
sentencing, the DROP File records are incorporated into a regular Central File that follows the
inmate for the remainder of incarceration. The DROP File contains records such as remand
orders, some displinary information, personal property records and routine custody related records.
Based on my experience, I requested staff at MCC New York conduct a search of inmate Epstein's
DROP file for a copy of his Intake Screening Form as that is the location most reasonably expected
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to locate the form. A review of inmate Epstein's DROP file did not produce records responsive to
Plaintiff's request for the Intake Screening Form. Based on my own experience and conversations
with MCC staff, there are no other locations reasonably expected to produce results.
18.
SECURITY DESIGNATION - Based on the experience and training of myself
and other staff involved in searching for records, it was determined that the SENTRY database
was the most likely place where "the security designation records for Jeffrey Epstein at MCC"
would be located. To search SENTRY for responsive information, staff used Jeffrey Epstein's
unique inmate register number of 76318-054 and the transaction codes of PPG0 for Security
Designation and PPG6 for Classification. The search returned the security designation for inmate
Epstein, and produced to Plaintiff in full on June 22, 2019.
19.
INMATE PROFILE - Based on the experience and training of myself and other
staff involved in searching for records, it was determined that the SENTRY database was the most
likely place where "the inmate profile for Jeffrey Epstein at MCC" would be located. To search
SENTRY for responsive information, staff used Jeffrey Epstein's unique inmate register number
of 76318-054 and the transaction code of PP44 for Inmate Profile. The search returned the inmate
profile security designation for inmate Epstein, and produced to Plaintiff in full on June 22, 2019.
20.
INCIDENT REPORTS - Based on the experience and training of myself and
other staff involved in searching for records, it was determined that the SENTRY database was the
most likely place where "[a]ll incident reports related to Jeffrey Epstein at MCC" would be located.
To search SENTRY for responsive information, staff used Jeffrey Epstein's unique inmate register
number of 76318-054 and the transaction code of PD15 for disciplinary history. This SENTRY
search returned the disciplinary history for inmate Epstein which was produced to Plaintiff in full
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on June 22, 2019, and one incident report for Epstein, which was withheld in full as noted in the
attached index at Entry 1.
21.
MEDICAL REPORTS - Based on the experience and training of myself and other
staff involved in searching for records, it was determined that the Bureau Electronic Medical
Record (BEMR) was the most likely place where "all medical reports related to Jeffrey Epstein at
MCC." BEMR is the electronic medical records repository for the BOP that contains all medical
records for inmates in BOP custody. To search BEMR for inmate related information, staff used
Jeffrey Epstein's unique inmate register number of 76318-054 to retrieve all of his medical records.
The search returned any medical, dental, optical and/or psychological records for inmate Epstein.
The psychological records were withheld in full, as noted on the attached index at Entry 19. BOP
is currently revewing the remaining BEMR records to segregate non-exempt information and
intends to release the records in part.
22.
VISITOR LOG - Based on the experience and training of myself and other staff
involved in searching for records, it was determined that the TRUVIEW database was the most
likely place where visitor log information for inmate Epstein would be located. TRUVIEW is a
BOP database that combines several inmate information databases (i.e., inmate finances, call lists,
messaging, visiting, and volunteer management) into one program. Regarding inmate visitors,
the TRUVIEW contains a log of all inmate visits. To search TRUVIEW for inmate related
information, staff used Jeffrey Epstein's unique inmate register number of 76318-054 to retrieve
all of his visitor information. The search returned the Federal Bureau of
Prisons/TRUVIEW/Inmate Center Report for inmate Epstein, produced to Plaintiff with redactions
on June 22, 2019. Scanned copies of certain log book pages showing visitors to Epstein were
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retained in the electronic files of certain individual staff members at MCC and were located
through their searches for these documents. The search returned two pages of scanned visitor
logs, which BOP is reviewing for segregable non-exempt information and intends to release in
part.
23.
MEETING DOCUMENTS - Based on the experience and training of myself and
other staff involved in searching for records, it was determined that a search of staff emails would
be the most likely way to locate records responsive to the request for "[d]ocuments showing when
MCC staff held meetings regarding Jeffrey Epstein, and who attended." The email search is
described in Paragraphs 44-46, infra. Additional searches for meetings documents are described
in the Declaraton of Nicole McFarland (the "McFarland Declaration").
24.
SUICIDE WATCH REMOVAL MEETING DOCUMENTS - Based on the
experience and training of myself and other staff involved in searching for records, it was
determined that a search of staff emails would be the most likely way to locate records responsive
to the request for "[a]ll records generated from the meeting at MCC during which it was decided
that Jeffrey Epstein would be taken off suicide watch." The email search is described in
Paragraphs 44-46, infra. Additional searches for meetings documents are described in the
McFarland Declaration.
25.
POST- WATCH REPORT - Based on the experience and training of myself and
other staff involved in searching for records, it was determined that a search of staff emails and
BEMR were the most likely ways to locate "the Post-Watch report compiled in order to take Jeffrey
Epstein off suicide watch." The email search is described in Paragraphs 44-46, infra, and the
BEMR search is described in Paragraph 21, supra. The BOP located the psychological records
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 12 of 34
for Epstein from BEMR, including a post-suicide watch report for Epstein prepared as part of his
removal from suicide watch, which was withheld in full, as noted in the attached index at Entry
19.
26.
OVERTIME SIGN-UP SHEETS - Based on the experience and training of
myself and other staff involved in searching for records, it was determined that a search of the
Roster/Overtime Program was the most likely place where "[t]he overtime sign-up sheets for the
Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and on July 22 and 23" would be
located. The Roster/Overtime Program is a web based program that allows staff to submit
overtime requests, submit Quarterly Preferences, view Daily Assignments, and view the
Mandatory Overtime List. The search returned the MCC daily assignment rosters for August 9
and 10, 2019, and July 22 and 23, 2019, which were withheld in full, except for one page released
in part from each roster on June 22, 2020, as noted in the attached index at Entries 7-9.
27.
STAFF AUGMENTING RECORDS - Based on the experience and training of
myself and other staff involved in searching for records, it was determined that a search of the
Roster/Overtime Program was the most likely place where "Documents showing which staff were
augmented at MCC and what positions they worked in on Aug. 9 and 10, and on July 22 and 23"
would be located. The search returned the MCC daily assignment rosters for August 9 and 10,
2019, and July 22 and 23, 2019, which were withheld in full, except for one page released in part
from each roster on June 22, 2020, as noted in the attached index at Entries 7-9.
28.
VIDEO CAMERA FOOTAGE - Based on the experience and training of myself
and other staff involved in searching for records, it was determined that the Special Investigativer
Agent's (SIA) office was the most likely place where video camera footage responsive to the
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 13 of 34
request for "[a]ll video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the
first suicide attempt" would be located. After consulting with the custodian for such records, it
was determined that the BOP does not have possession of responsive records because all
video/NICE vision equipment was handed over to the FBI on or about August 10, 2019.
29.
The BOP sought to preserve video footage from July 23, 2019, the night of
Epstein's apparent suicide attempt, pursuant to a preservation request in a criminal case.
However, the BOP inadvertently preserved footage showing a different area within MCC, and the
video footage from the SHU at MCC no longer exists on the backup system because of a technical
error. See Letter from the Government dated January 9, 2020, Dkt. No. 182, United States V.
Tartaglione, No. 16-cr-832 (KMK).
30.
SUICIDE ATTEMPT AND SUICIDE RECORDS - Based on the experience
and training of myself and other staff involved in searching for records, it was determined that a
search of the Bureau Electronic Medical Record (BEMR) and a search for Forms 583 and related
documents were the best methods to locate records responsive to the request for "[a]ll BOP
documents pertaining to Jeffrey Epstein's suicide and first suicide attempt." To locate medical
and psychological records responsive to this request, BOP searched BEMR. BOP's BEMR
search is detailed supra at Paragraph 21. The psychological records were withheld in full, as noted
on the attached index at Entry 19. BOP is currently revewing the remaining BEMR records to
segregate non-exempt information and intends to release the records in part.
31.
With regard to the Form 583 and related documents, MCC Staff located the Form
583 and related documents concerning Epstein's apparent suicide attempt on July 23, 2019 as
described in the McFarland Declaration. Because staff at MCC New York did not have access to
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the Form 583 and related documents concerning Epstein's suicide on August 10, 2019, I requested
these records from the Correctional Programs Division in the Central Office of the Bureau of
Prisons (BOP). Based on my knowledge and experience, I am aware that the Correctional
Programs Division (CPD) has access to all Form 583s and related documents regardless of the
institution that created the Form 583 as they are the Division that has overall responsibility for all
Correctional Services Departments in the BOP. Accordingly, once I became aware staff at MCC
New York no longer had access to the Form 583 and related documents from August 10, 2019,
knowing that the CPD was the location most reasonably expected to maintain the Form 583 and
related documents concerning Epstein's suicide on August 10, 2019, I requested, and received, the
records from them. The 583 Forms were withheld in full, as noted in the attached Index at Entries
15 and 18.
32.
BOP staff also located additional reports prepared following Epstein's apparent
suicide attempt and Epstein's suicide, including a psychological reconstruction of inmate death
and responses thereto, including a memorandum; a document titled MCC New York Updates; draft
letters to Epstein's brother, Chief Judge McMahon and Judge Berman; a letter to the MCC warden
dated August 14, 2019; photo sheets from Epstein's July 23, 2019 apparent suicide attempt and
Epstein's August 10, 2019 suicide, a chain of custody form from Epstein's July 23 apparent suicide
attempt, reports of the July 23, 2019 apparent suicide attempt, memoranda and reports of Epstein's
August 10, 2019 suicide. MCC staff located these documents by manually searching their files for
records pertaining to Epstein's July 23, 2019 apparent suicide attempt and Epstein's August 10,
2019 suicide. These records were withheld in full or withheld in part as noted in the attached Index
at Entries 2, 10, 11, 12, 13, 14, 16, 17, 18, 20, 35, and 36.
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33.
SUICIDE WATCH REMOVAL DOCUMENTS - Based on the experience and
training of myself and other staff involved in searching for records, it was determined that, in
addition to any records that may exist in the BEMR for inmate Epstein, a search of staff emails
was the other place where records responsive to the request for "[a]ll BOP documents, including
email correspondence and meeting minutes, pertaining to the decision to remove Jeffrey Epstein
from suicide watch" would be. The email search is described in Paragraphs 44-46, infra, and the
scope and results of the BEMR search are described in Paragraph 28, supra. These records were
withheld in full as noted in the attached Index at Entries 19 and 52. Additional searches for
documents pertaining to the decision to remove Epstein from suicide watch are described in the
McFarland Declaration.
34.
SPECIAL INVESTIGATIVE REPORTS - Based on the experience and training
of myself and other staff involved in searching for records, it was determined that a search of the
BOP Special Investigative Section ("SIS") database known as TRUINTEL was the best way to
locate records responsive to the request for "[a]ll BOP special investigation reports mentioning
Jeffrey Epstein." The SIS database contains information related to investigation of both inmates
and staff. To search the SIS database for special investigation reports about inmate Epstein, staff
used inmate Epstein's unique inmate register number of 76318-054 to retrieve any and all special
investigative reports maintained by the BOP about inmate Epstein. The search returned one
Inmate Investigative Report for inmate Epstein, which was withheld in full, as noted on the
attached index at Entry 9.
35.
CORRESPONDENCE - Based on the experience and training of myself and other
staff involved in searching for records, it was determined that a search of staff emails was the most
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effective way to locate records responsive to the request for "[a]ll BOP correspondence with the
U.S. Attorney's Office regarding Jeffrey Epstein." The email search is described in Paragraphs
44-46, infra.
36.
PHONE LOGS - Based on the experience and training of myself and other staff
involved in searching for records, it was determined that a search of the TRUVIEW database was
the most likely place where a "full log of Mr. Epstein's phone calls to and from the MCC" would
be located. Regarding inmate telephone calls, TRUVIEW contains a list of all people who were
approved to be on inmate Epstein's telephone list, and it also has a log of all inmate telephone calls
not made on a legal line. To search TRUVIEW for inmate related information, staff used Jeffrey
Epstein's unique inmate register number of 76318-054 to retrieve all of his telephone call
information. The search returned the Federal Bureau of Prisons/TRUVIEW/Inmate Center
Report for inmate Epstein, produced to Plaintiff with redactions on June 22, 2019.
37.
EMAIL COMMUNICATIONS - Based on the experience and training of myself
and other staff involved in searching for records, it was determined that the TRULINCS database
was the most likely place where "[a]ll email correspondence to and from Mr. Epstein while he was
at the MCC (including any correspondence through the Corrlinks system or any other email system
he had access to[]" would be located. TRULINCS is a BOP database that is comprised of two
main components. One component is the inmate application used solely by the inmates and
provides inmates the capability to manage their contact list for emails, communicate with members
of the public on an inmate's contact list via email, and communicate with staff. To search
TRULINCS for inmate related information, staff used Jeffrey Epstein's unique inmate register
number of 76318-054 to check for email communications to and from inmate Epstein. The search
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did not return any results for emails to/from Epstein's TRULINCS account - either to/from any
member of the public or to/from staff.
38.
VISITOR LOGS - Based on the experience and training of myself and other staff
involved in searching for records, it was determined that a search of the TRUVIEW database was
the most likely place where "[t]he full log of people who visited Mr. Epstein while he was at the
MCC and when they visited" would be located. Regarding inmate visitors, the TRUVIEW
contains a log of all inmate visits. To search TRUVIEW for inmate related information, staff
used Jeffrey Epstein's unique inmate register number of 76318-054 to retrieve all of his visitor
information. The search returned the Federal Bureau of Prisons/TRUVIEW/Inmate Center Report
for inmate Epstein, produced to Plaintiff with redactions on June 22, 2019.
39.
In addition, staff at MCC searched for physical visitor logs and located one log
book showing a visitor for Jeffrey Epstein on July 30, 2019. A copy of the page from the log
book showing this visit was produced to the Plaintif with redactions on June 22, 2019. All other
physical visitor logs were handed over to the OIG on or about August 22, 2019, and the BOP is no
longer in possession of these logs.
40.
VISITOR LISTS - Based on the experience and training of myself and other staff
involved in searching for records, it was determined that a search of the TRUVIEW database was
the most likely place where "[t]he full list of people that Mr. Epstein had requested to be on his
approved visitor list." would be located. To search TRUVIEW for inmate related information,
staff used Jeffrey Epstein's unique inmate register number of 76318-054 to retrieve all of his visitor
information. The search returned the Federal Bureau of Prisons/TRUVIEW/Inmate Center
Report for inmate Epstein, produced to Plaintiff with redactions on June 22, 2019.
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41.
EMAIL LIST - Based on the experience and training of myself and other staff
involved in searching for records, it was determined that a search of the TRUVIEW database was
the most likely place where "[t]he full list of people that Mr. Epstein had requested to be on his
approved email correspondence list" would be located. To search TRUVIEW for inmate related
information, staff used Jeffrey Epstein's unique inmate register number of 76318-054 to retrieve
all
of his visitor information. The search returned the Federal Bureau of
Prisons/TRUVIEW/Inmate Center Report for inmate Epstein, produced to Plaintiff with redactions
on June 22, 2019.
42.
APPROVED CALL LIST- Based on the experience and training of myself and
other staff involved in searching for records, it was determined that a search of the TRUVIEW
database was the most likely place where "[t]he full list of people that Mr. Epstein had requested
to be on his approved call list" would be located. Regarding inmate approved call lists, the
TRUVIEW database contains a log of all people who are approved to be on an inmate's call list.
To search TRUVIEW for inmate related information, staff used Jeffrey Epstein's unique inmate
register number of 76318-054 to retrieve all of his visitor information. The search returned the
Federal Bureau of Prisons/TRUVIEW/Inmate Center Report for inmate Epstein, produced to
Plaintiff with redactions on June 22, 2019.
43.
RECORDINGS OF TELEPHONE CALLS - Based on the experience and
training of myself and other staff involved in searching for records, it was determined that the
TRUVIEW database was the most likely place where the approved call list information for inmate
Epstein would be located to determine if there were any "recordings of the last three phone
conversations that Mr. Epstein had." To search TRUVIEW for inmate related information, staff
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used Jeffrey Epstein's unique inmate register number of 76318-054 to retrieve all of his call
information. The search returned the Federal Bureau of Prisons/TRUVIEW/Inmate Center
Report for inmate Epstein, produced to Plaintiff with redactions on June 22, 2019. Epstein did
not have any calls listed there, and so no recordings of Epstein's calls were located. As noted
above, Epstein did make telephone calls on the legal line at the MCC, but these calls were
unmonitored, unrecorded and not logged in TRUVIEW, such that there is no system to search for
records of them.
III. BOP'S EMAIL SEARCH
44.
Below is a description of the email search for records as it relates to requests for
which a search of email records was conducted, as noted above. Based on the experience and
training of myself and other staff involved in searching for records, it was determined that a
search of the BOP's GROUPWISE email system was appropriate as GROUPWISE is the BOP's
email client platform for staff. Based on the scope of the requests, the GROUPWISE email
accounts for the below identified BOP staff was the most likely place where communications
about inmate Epstein would likely be located, as these BOP staff were key decision makers at
the institution, regional, and central office levels of the BOP and were likely involved and likely
made recommendations about Mr. Epstein's classification while he was confined at MCC New
York. The email search was conducted using both the staff member's name and his or her
unique BOP identifier and other particularized search terms based on the Plaintiff's FOIA
Requests. The staff whose emails were searched were as follows:
(1)
Acting Director Hurwitz;
(2)
Former Regional Director Johnathan Ray Ormond;
(3)
Regional Counsel Darrin Howard;
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(4)
Deputy Regional Counsel Adam Johnson;
(5)
Correctional Programs Administrator Sukenna Stokes;
(6)
Warden Lamine N'Diaye;
(7)
Associate Warden Shirley Skipper Scott;
(8)
Associate Warden Charisma Edge;
(9)
Associate Warden Brian Best;
(10)
Executive Assistant Lee Plourde;
(11)
Supervisory Attorney Nicole McFarland;
12)
Captain Jermaine Darden; and
(13)
Chief of Psychology Elissa Miller.
45.
Based on the scope of the FOIA request, the search terms used for the search and
the date range for the search were as follows:
(1)
Jeffrey Epstein, 76318-054, MCC, New York, meetings, suicide watch,
suicide, AUSA, USAO and
(2)
7/6/2019 (Date Epstein went into custody at MCC) through 1/9/2020 (the
date of Complainant's last FOIA Request).
46.
The email search produced 1911 records, which totaled 18,062 pages. After
review of the records, it was determined that 3176 pages of these records were responsive and
non-duplicative.
III. APPLICATION OF EXEMPTIONS
Segregability
47. I and other FOIA staff reviewed and continue to review the records located in
response to Plaintiff's FOIA requests to determine whether or not there is any non-exempt
information in the records that could be reasonably segregated and released. We have already
determind that 584 pages contain such information, and those pages were released, with
appropriate redactions, to Plaintiff on June 22, July 7, and July 10. Other than these 584 pages
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and the records listed as withheld in full on the attached index, I and other FOIA staff continue to
review the remaining records because we currently believe that they contain segregable
information, such that the additional records could be released in part. Each of the records
withheld in full includes exempt information that is inextricably intertwined with any non-
exempt information in the document, such that segregating any non-exempt information would
be of little to no informational value.
48. All of the responsive records withheld in full by BOP are withheld under FOIA
Exemption 7(A), except for the 2 pages of draft letters at Entry 11 of the attached index and the
57 pages of email records at Entry 54 of the attached index, withheld under Exemption 5 and
discussed below. The basis for withholdings under Exemption 7(A) is explained in the
accompanying declaration of Counsel to the Acting United States Attorney Russell Capone. In
addition to the withholdings in full under Exemptions 7(A) and 5, BOP has also withheld certain
records or portions of records under Exemptions 5, 6, 7(A), 7(C), 7(E), and 7(F).
A.
Withholdings under Exemption 5
49.
Title 5 U.S.C. $ 552(b)(5) ("Exemption 5") excludes from disclosure "inter-
agency or intra-agency memorandums or letters which would not be available by law to a party
in litigation with the agency." 5 U.S.C. $ 552(b)(5). Exemption 5 incorporates all the normal
civil discovery privileges, including the deliberative process privilege andand the attorney-client
privilege. BOP has withheld records in full and in part under the deliberative process privilege.
As noted in the attached index, BOP has withheld in full under the deliberative process privilege
the incident report for Epstein's July 23, 2019 apparent suicide attempt, the psychological
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reconstruction of Epstein's suicide and responses thereto, and draft letters to Epstein's brother
and Chief Judge McMahon and Judge Berman.
a. The incident report for Epstein's July 23, 2019, apparent suicide attempt is
predecisional because it preceded the decisions to remove Epstein from
suicide watch and to house him in a particular cell in the SHU with a cellmate.
Decisions concerning cell designation for inmates and whether to cell an
inmate with another inmate or with a particular inmate are policy decisions
involving open and frank conversations by senior BOP staff to include
security staff, medical staff, unit staff, and executive staff. These discussions
are particularly amplified when dealing with high profile inmates and for
which the inmate's incarceration with the BOP is the subject of great media
and public attention. Thus, the incident report was prepared to assist BOP in
making those decisions because it documents details of Epstein's apparent
suicide attempt that were relevant to the determination of whether he would be
removed from suicide watch and how and where he would be housed
thereafter. It was deliberative because it bears on the exercise of a policy-
oriented judgment by assisting in the application of BOP's policies of
releasing certin inmates from suicide watch and housing them in specific
circumstances based on details of their psychological profile and any suicide
attempt. Release of the incident report would hamper BOP employees'
abilities to frankly discuss the circumstances of suicide attempts and assess
BOP's suicide prevention policies.
b. The psychological reconstruction of Epstein's suicide and responses thereto
are predecisional because they preceded BOP's decisions regarding how to
respond to Epstein's suicide and was prepared to assist in deciding which
actions to take. Specifically, the psychological reconstruction report was part
of a review by BOP following Epstein's suicide of MCC's suicide prevention
policies, including a determination of whether MCC's suicide prevention
policies needed to be changed. It was also part of a review to determine
whether or not wider changes, such as changes in personnel or leadership at
MCC, were necessary. Further, the purpose of the report is to provide Senior
BOP staff information for which to consider future policy considerations
throughout the BOP concerning the care and custody of inmates. Thus, these
reports are ultimately recommendations in that they not only point out factual
information, but with this factual information Senior BOP staff are able to
consider strategic initiatives. The report is deliberative because it contains
multiple recommendations-and responses to certain recommendations-for
how MCC should change its suicide preventation policies and measures,
including, for example, recommendations about double-celling and direct
observation of inmates, duration of suicide watches, how to structure such
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watches. These recommendations are used by Senior BOP officials in terms
of policy considerations that impact BOP operations across facilities.
Further, any such recommendations are discussed by Senior BOP officials and
as such requires the frank and open assessment by these officials in reaching a
decision to adopt a policy recommendation. Release of the report would
hamper frank and open discussions and assessments by these officials in
reaching policy decisions.
c. The draft letters are predecisional because they were prepared in advance of
final letters sent to individuals and to assist in determining the content of the
final letters. Agency formal letters are purposed as final Agency policy
directives and members of the public and press view Agency letters no
differently than officially adopted policy statements. As such, draft letters
are not the Agency's final response and like other policy related documents,
Agency letters are not an official statement of the Agency until a final letter is
prepared and dispatched They are deliberative because they bear on the
exercise of a policy-oriented judgment in that they are part of BOP's
determination of how best to inform family members and other relevant
parties of the death of an inmate. Their release would harm BOP's ability to
determine how best to inform family members and other relevant parties of
the death of an inmate.
Certain email records have also been withheld in part under the
deliberative process privilege.
d. One category of emails pertains to Epstein's July 23, 2019, apparent suicide
attempt and incarceration. These emails are predecisional because they were
prepared to assist BOP in making decisions about Epstien's incarceration,
including whether he would remain -on suicide watch and whether he would
be housed with a cellmate. They are deliberative because they bear on the
exercise of a policy-oriented judgment, namely the application of BOP's
policies of releasing certin inmates from suicide watch and housing them
under particularized housing measures, including based on details of their
psychological profile and any suicide attempt. The decision to place an
inmate on suicide watch or to remove an inmate from suicide watch involves
involves policy deliberations from several BOP senior level stakteholders
from medical staff, psychology staff, Correctional Program Division Staff,
security staff, and executive staff. Release of the information in these emails
would hamper BOP's employees' ability to frankly discuss decisions
regarding placing inmates on and removing inmates from suicide watch and to
discuss suicide prevention policies.
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 24 of 34
e. One category of emails pertains to press inquiries concerning Epstein and his
death and how BOP will respond to them. They are predecisional because
they were prepared in advance of BOP's decisions regarding whether and how
to change policies at MCC, including suicide prevent policies, following
Epstein's death and in advance of BOP's decisions regarding whether and
how to respond to press inquiries about Epstein. They were prepared to assist
in how deciding how BOP would respond to inquiries because they are
communications, including deliberations, between BOP employees about how
to respond. They are deliberative because they consist of BOP's
considerations of how to respond and include drafts of responses to press
inquiries and discusions of what responses should be provided. They are also
deliberative because they bear on BOP's decisions regarding whether and how
polcies at MCC, including suicide prevention policies, should change, in that
they include details of Epstein's death, the response or reaction of BOP
employees to details of Epstein's death, and discussion of steps taken at MCC
following Epstein's death, including responding to press inquiries. Release of
the information in these emails would hamper BOP's decisionmaking
processes in determining how to communicate with the press and its
assessment of policies at facilities where suicides occur.
f. One category of emails pertains to Epstein's suicide and BOP's response to
Epstein's suicide. They are predecisional because they preceded BOP's
decisions regarding how to respond to Epstein's suicide and were prepared to
assist in deciding -areas of policy consideration for the BOP's suicide
preventation strategies. Specifically, they relate to deliberations within BOP
and MCC following Epstein's suicide about MCC's policies, including its
suicide prevention policies. They are deliberative because they include
communications that were part of a review to determine whether or not policy
changes, such as changes in suicide perevention policies, personnel or
leadership at MCC, were necessary. Release of the emails would hamper BOP
employees' frank discussion of suicide prevention policies (and leadership
and personnel decisions) at its facilities and whether it is necessary to change
these policies (or leadership or personnel).
50. As indicated at Entry 54 in the attached index, one 56-page set of emails was
withheld in full under the attorney-client privilege. This group of withheld emails consists of
communications between BOP employees and BOP's attorneys, Assistant United States
Attorneys in the Civil Division of the USAO-SDNY, concerning requests for documents related
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 25 of 34
to Epstein, preservation of documents related to Epstein, and how to respond to requests pursuant
to Department of Justice regulations (known as Touhy regulations). As communications
between attorneys and a client, these emails were properly withheld under Exemption 5. Release
of these emails would negatively affect BOP's ability to seek out and receive frank legal counsel.
Threshold Justification For Application of Exemption 7
51. As a threshold to applying Exemption 7, an agency has to demonstrate that the
"records or information [were] compiled for law enforcement purposes." 5 U.S.C. $552(b)(7).
52. The BOP is a law enforcement agency. The term "law enforcement officer" is defined
as "an employee of the Bureau of Prisons or Federal Prison Industries, Inc." See, e.g., 5 U.S.C.
§ 8401(17)(D)(i). Furthermore, BOP employees perform law enforcement functions. They
possess the authority to make arrests, 18 U.S.C. $ 3050; seize evidence, 18 U.S.C. $ 4012; and
execute searches on inmates and visitors to the institution, 28 C.F.R. §§ 511.10-511.12, 552.10-
552.14. Additionally, the BOP is tasked with the law enforcement mission of protecting inmates,
staff, and the community. See 18 U.S.C. § 4042(a)(1)-(3) ("The Bureau of Prisons, under the
direction of the Attorney General, shall (1) have charge of the management and regulation of all
Federal penal and correctional institutions; (2) provide suitable quarters and provide for the
safekeeping, care, and subsistence of all persons charged with or convicted of offenses against the
United States, or held as witnesses or otherwise; (3) provide for the protection, instruction, and
discipline of all persons charged with or convicted of offenses against the United States
").
53. All of the records withheld in full or in part were compiled for law enforcement
purposes because they were compiled in the exercise of BOP's statutory authority to detain
arrested individuals before trial pursuant to a judicial order. All of these records relate to a
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=== Page 26 ===
Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 26 of 34
specifically identified inmate and concern the conditions of his incarceration (including his
housing location, medical records, visitor lists, security designation, staff decisions concerning
the inmate's status at MCC New York, and the like). They were compiled in order to carry out
BOP's responsibilities to protect the safety, security, and orderly operation of BOP facilities,
specifically MCC New York, to protect the public, and/or to protect the safety and care of the
inmate who is the subject of the records in question. In addition, some of the records were
compiled as part of the investigations into Epstein's incarceration and death and serve as
investigatory tools. Some were also compiled for the specific law enforcement of purpose of
preventing suicides at BOP facilities and ensuring the safety of inmates in BOP facilities. The
records at issue in this FOIA request meet the law enforcement threshold of Exemption (b)(7).
Records Withheld Pursuant to Exemptions 6 and 7(C)
54.
U.S.C. § 552(b)(6), ("FOIA Exemption 6"), protects from disclosure "personnel
and medical files and similar files the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy." 5 U.S.C. $ 552(b)(6).
55.
U.S.C. § 552(b)(7)(C) ("Exemption 7(C)") exempts from disclosure records or
information compiled for law enforcement purposes where its production "could reasonably be
expected to constitute an unwarranted invasion of personal privacy." 5 U.S.C. $ 552(b)(7)(C).
56.
Some of the records withheld by BOP contain contain personal information
withheld in part under Exemptions 6 and 7(C) (the "6 & 7(C) Records"). The 6 & 7(C) Records
include personnel files within the meaning of Exemption 6, such as overtime logs for the MCC.
The remainder of the 6 & 7(C) records are "similar files" within the meaning of Exemption 6
because they contain information about particular, identifiable individuals. This information
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includes personally identifying information, such as names and contact information, of various
third-party individuals other than Epstein.
57.
Exemptions 6 and 7(C) each require a balancing of the privacy interests
implicated by disclosure of a record with the public interest in its disclosure. The privacy
interests implicated by the 6 & 7(C) Records include the privacy interests of BOP employees,
BOP inmates other than Epstein, Epstein's surviving family members, visitors or senders of
funds to BOP inmates, legal counsel for BOP inmates, USAO-SDNY employees, and journalists.
The 6 & 7(C) Records contain personally identifying information, such as names and contact
information, for each of these categories of individuals and detail their association with Epstein
or their involvement or interest in Epstein's incarceration, death, or the response of BOP or the
USAO-SDNY to Epstein's death. Release of this information - particularly in light of the
intense media interest in and public speculation concerning Epstein's death - could reasonably be
expected to expose these third parties to unwanted scrutiny, embarrassment, and even harassment
or retaliation.
58.
The sole public interest to be weighed against these privacy interests under both
Exemption 6 and 7(C) is the public's understanding of government operations. The personal
information withheld from the 6 and 7(C) Records will not significantly contribute to the
public's understanding of the operation or activities of the government or further the purpose of
the FOIA by informing the public of the government's activities. The withheld personal
information does not provide significant insight into government activities or operations in
connection with Epstein's incarceration or the response of BOP, the USAO-SDNY, or any other
government agency to Epstein's death. For example, the names of BOP employees in the
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 28 of 34
withheld records do not provide members of the public with a greater understanding of how BOP
works.
59.
The large volume of publicity and often unfounded speculation concerning the
circumstances of Epstein's death increase the likelihood that disclosure of the information
withhed under Exemptions 6 and 7(C) would cause an unwarranted invasion of personal privacy.
60.
In light of the public and unfounded speculation on Epstein's death and the media
coverage thereof, it is reasonable to expect that individuals identified through disclosures by the
government as associated with Epstein's incarceration and death, or investigation of the charges
against Epstein or the circumstances of his death, could be targeted or harassed. Accordingly,
publicizing the identity, contact information, or other personal information of a particular
individual's associations or interactions with Epstein, or participation in the investigation of and
response to his death, will amount to a significant invasion of personal privacy, with no
meaningful contribution to the public's understanding of how the government works.
61.
For each category of individuals with personally identifying information present
in the 6 & 7(C) Records, the individual privacy concerns outweigh the putative public interest in
their disclosure.
a. The disclosure of personally identifying information of BOP employees, such
as their names or contact information, would significantly invade their
personal privacy without contributing to a public understanding of how BOP
works. As noted above, disclosing the names or contact information of BOP
employees does not provide insight into how BOP works because individual
employees' names or contact information are not relevant to how BOP works.
b. The disclosure of personally identifying information of BOP inmates, such as
their names or contact information, would significantly invade their personal
privacy without contributing to a public understanding of how BOP works.
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The names or contact information of particular inmates is not relevant to and
provides no greater understanding of how BOP works.
c. The disclosure of personally identifying information of visitors or senders of
funds to BOP inmates, such as their names and contact information, would
significantly invade their personal privacy without contributing to a public
understanding of how the government works: identification of the individuals
who visited or sent money to Epstein or other inmates does not shed light on
BOP conduct or how BOP or any other government agency works.
d. The disclosure of personally identifying information of legal counsel to
Epstein and other BOP inmates, such as their names and contact information,
would significantly invade their personal privacy without contributing to a
public understanding of how the government works: identification of counsel
to Epstein and other inmates does not shed light on BOP conduct or how BOP
or any other government agency works.
e. The disclosure of personally identifying information of USAO-SDNY
employees, such as their names and contact information, would significantly
invade their personal privacy without contributing to a public understanding
of how the USAO-SDNY works: the particular names or contact information
of USAO-SDNY employees is not relevant to and does not provide any
insight into how the USAO-SDNY operates.
f. The disclosure of personally identifying information of journalists, such as
their names and contact information, would significantly invade their personal
privacy without contributing to a public understanding of how the government
works: the provision of information about journalistic approaches to gathering
information is not a public interest protected by Exemption 6 or 7(C).
62. Some of the 6 & 7(C) Records also contain information implicating the privacy
interests of Epstein's surviving family. These records contain highly personal details about
Epstein's suicide, including graphic images of his body after he committed suicide. Release of
images of a deceased family member's body and the details of his suicide could reasonably be
expected to cause hardship and pain to surviving family members by interfering with their
mourning or remembering of the deceased person. The publicity and unfounded speculation
surrounding Epstein's death would heighten this risk of hardship and pain. The release of records
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Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 30 of 34
containing highly personal details about Epstein's suicide, such as photographs of his body,
would clearly constitute (and, at a minimum, could reasonably be expected to constitute) an
unwarranted invasion of his family members' personal privacy. Such details about Epstein's
suicide provide no significant information to the public about how the government works.
63.
The release of the personally identifying information in the 6 & 7(C) records
would clearly constitute (and, at a minimum, could reasonably be expected to constitute) an
unwarranted invasion of the personal privacy of of BOP employees, BOP inmates other than
Epstein, Epstein's surviving family members, visitors or senders of funds to BOP inmates, legal
counsel for BOP inmates, USAO-SDNY employees, or journalists.
Records Withheld Pursuant to Exemption 7(E)
64.
Title 5 U.S.C. $ 522 (b)(7)(E) ("Exemption 7(E)") exempts from disclosure
"records or information compiled for law enforcement purposes, but only to the extent that the
production of such law enforcement records or information
would disclose techniques and
procedures for law enforcement investigations or prosecutions, or would disclose guidelines for
law enforcement investigations or prosecutions if such disclosure could reasonably be expected
to risk circumvention of the law."
65.
Some of the records withheld by BOP contain information or discussion of law
enforcement techniques and procedures or guidelines for law enforcement investigations or
prosecutions, as indicated on the attached index (the "7(E) Records"). As explained above, all
of the records withheld in full or in part, including the 7(E) Records, were compiled for law
enforcement purposes, including the incarceration of Epstein or other inmates and the
investigation of the circumstances of Epstein's death.
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66.
The 7(E) Records fall wholly or in part within the scope of Exemption 7(E)
because they include information or discussions that would disclose law enforcement techniques
and procedures and their use in investigating incidents that occurred during Epstein's
incarceration, including his suicide. Specifically, in terms of non-email records, as noted in the
attached index, the psychological reconstruction of Epstein's suicide and responses thereto
would disclose BOP's techniques and procedures in investigating inmate suicides. More
specifically, disclosure of this report will reveal the specific techniques the BOP uses to
reconstruct a suicide to include its information and evidence gathering strategies. Revealing this
information to third parties will allow inmates the ability to learn how to manufacture and then
subsequently disguise their instruments used to commit suicide. When inmates are armed with
this information, it will prevent staff from locating these instruments during the routine course of
cell checks and contraband searches. This will lead to more suicide attempts and ultimately,
successful suicides by inmates.
67.
The Inmate Investigative Report would disclose BOP's techniques and procedure
in investigating incidents involving inmates, which could lead to inmates taking actions to
circumvent BOP's investigatory techniques. The MCC New York Updates would disclose how
BOP investigates and tracks certain incidents and events within its facilities. The letter to the
MCC warden regarding a visit by an after action team would disclose BOP's investigatory
techiniques and procedures for investigating inmate suicides. The photo sheets from Epstein's
July 23 apparent suicide attempt, a chain of custody form from Epstein's July 23 apparent
suicide attempt, memoranda and reports of the July 23 apparent suicide attempt, and the Form
583 for Epstein's apparent suicide attempt would disclose BOP's investigatory techniques and
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procedures for investigating inmate suicide attempts. The release of the same will permit
inmates to circumvent detection by staff of potential risks of suicides and thus increase the risk
inmates will successfully commit suicide. Suicide attempts and successful suicides not only
create a risk of danger and harm to the inmate attempting a suicide, but also place an inmate's
cellmate in danger and place staff who respond to the attempted suicide or completed suicide in
danger.
68.
Certain email records also contain information falling within the scope of
Exemption 7(E). First, some emails pertaining to Epstein's July 23, 2019, apparent suicide
attempt and his incarceration at MCC New York contain information that would would disclose
BOP's investigatory techniques and procedures for investigating inmate suicide attempts. The
release of the same will permit inmates to circumvent detection by staff of potential risks of
suicides and thus increase the risk that an inmate will successful commit suicide. Second, some
emails pertaining to Epstein's suicide and BOP's response to Epstein's suicide contain
information that would disclose BOP's investigatory techniques and procedures for investigating
inmate suicides.
Records Withheld Pursuant to Exemption 7(F)
69.
Title 5 U.S.C. $ 522 (b)(7)(F) ("Exemption 7(F)") exempts from disclosure
"records or information compiled for law enforcement purposes, but only to the extent that the
production of such law enforcement records or information
could reasonably be expected to
endanger the life or physical safety of any individual."
70.
Some of the records withheld by BOP contain the personally identifying
information, such as names and contact information, of third-party individuals involved in law
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enforcement investigations, as indicated on the index prepared by BOP (the "7(F) Records").
Each of the 7(F) Records were compiled for law enforcement purposes, namely the incarceration
of Epstein or the response of the USAO-SDNY and BOP to Epstein's death.
71.
The 7(F) Records fall in part within the scope of Exemption 7(F) because the
release of the personally identifying information contained in these records could reasonably be
expected to endanger the life or physical safety of BOP employees and USAO-SDNY employees
whose personally identifying information is contained in the 7(F) Records. BOP and USAO-
SDNY employees work with inmate and criminal defendants who, upon their release from
incarceration or during their incarceration, might target BOP or USAO-SDNY employees for
reprisal, who in many metropolitan cities live in the cities where they work, who frequently
utilize public transportation, and who regularly engage in community and social activities in
those cities. The release of personally identifying information of BOP or SDNY-USAO
employees increases the risks of such targeting or harassment because it would make it easier for
identified employees to be targeted or harassed. Because of the attention and speculation
surrounding Epstein's death, it is reasonable to expect that individuals identified through
disclosures by the government as associated with Epstein's incarceration and death, investigating
the charges against Epstein, or investigating the circumstances of Epstein's death could be
targeted.
Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is
true and correct.
33
EFTA00015393

=== Page 34 ===
Case 1:20-cv-00833-PAE Document 24 Filed 08/05/20 Page 34 of 34
Executed this 5th day of August 2020.
Kara Christenson
Kara Christenson
Government Information Specialist
FOIA/PA Section (Central Office)
Bureau of Prisons
34
EFTA00015394

=== Page 35 ===
Case 1:20-cv-00833-PAE Document 24-1 Filed 08/05/20 Page 1 of 6
Attachment 1
EFTA00015395

=== Page 36 ===
Page 1 of 5
Case 1:20-cv-00833-PAE Document 24-1 Filed 08/05/20 Page 2 of 6
OGC Electronic Freedom of Information - NYT FOIA request -- BOP #1, filed 8/13/19
From:
"Ivory, Danielle" <danielle.ivory@nytimes.com>
To:
<OGC_EFOIA@bop.gov>
Date:
8/13/2019 4:58 PM
Subject: NYT FOIA request -- BOP #1, filed 8/13/19
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of any help in explaining this
or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone: 212-556-1596
Mobile phone: 917-280-2607
Email: danielle.ivory@nytimes.com
Aug. 13, 2019
Bureau of Prisons
OGC_EFOIA@BOP.GOV
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise
produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed
forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs,
EFTA00015396

=== Page 37 ===
Page 2 of 5
Case 1:20-cv-00833-PAE Document 24-1 Filed 08/05/20 Page 3 of 6
minutes of meetings, records of meetings in any form, and any other compilation of data from which
information can be obtained. All of the foregoing are included in this request if they are in the
possession of or otherwise under the New York Times requests for Records of the following type in the
possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of
(or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"):
(1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July
22 and 23, and Aug. 9 and 10.
(2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC.
(3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC.
(4) The chronological disciplinary records for Jeffrey Epstein at MCC.
(5) The intake screening form for Jeffrey Epstein at MCC.
(6) The security designation records for Jeffrey Epstein at MCC.
(7) The inmate profile for Jeffrey Epstein at MCC.
(8) All incident reports related to Jeffrey Epstein at MCC.
(9) All medical reports related to Jeffrey Epstein at MCC.
(10) The signed visitor log for Jeffrey Epstein at MCC.
(11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended.
(12) All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein
would be taken off suicide watch.
(13) The Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch.
(14) The overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and
on July 22 and 23.
(15) Documents showing which staff were augmented at MCC and what positions they worked in on
Aug. 9 and 10, and on July 22 and 23.
EFTA00015397

=== Page 38 ===
Page 3 of 5
Case 1:20-cv-00833-PAE Document 24-1 Filed 08/05/20 Page 4 of 6
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the
BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau.
I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I
request the Records to inform the public about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending investigations, you may not assert
Exemption 7(A) without conducting a document-by-document review to determine whether release of
the records would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation
to conduct record-level reviews at the administrative level before refusing to produce records contained
in its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to
withhold records only when their release would work some foreseeable or is prohibited by law, not just
because they may technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them only if their disclosure
would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5
U.S.C 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from
release of the information being withheld, consider partial disclosure of the information, take reasonable
steps to segregate and release nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business days. This request is
segregable, and your agency may not withhold entire records because of one section that you believe
is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records
from disclosure, you must specify in a written response the factual and legal basis for withholding any
part of the Records.
EFTA00015398

=== Page 39 ===
Page 4 of 5
Case 1:20-cv-00833-PAE Document 24-1 Filed 08/05/20 Page 5 of 6
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C.
$ 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion
of the request needs to be processed by another agency, please inform me which agency that is and
whether it has provided you with an estimated date of completion.
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer files in the same format as
they are currently maintained at the agency, pursuant to Burka V. Dept. of Health & Human Svcs., 87
F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing
hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. $
552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records.
FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the
public's "right to be informed about what their government is up to." U.S. Dep't of Justice V. Reporters
Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted).
In order to provide public access to this information, FOIA's fee waiver provision requires "[d]ocuments
shall be furnished without any charge or at a [reduced] charge disclosure of the information is in the
public interest because it is likely to contribute significantly to public understanding of the operations or
activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. $
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who
was accused of sexually abusing scores of women and underage girls. Not only has a person died in
federal custody, but the death has generated multiple conspiracy theories implicating government
works at the highest levels and taxpayer money. Disclosure of the records request is in the public
interest because disclosure is likely to contribute significantly to the understanding of the operations or
activities of the government. In addition, as one of the largest circulation newspapers in the United
States, The New York Times plays an important role in sharing information with the public and helping
the public understand how the federal government works. Disclosure of the records is not primarily in
the commercial interest of myself or The New York Times but is intended to facilitate reporting on the
EFTA00015399

=== Page 40 ===
Page 5 of 5
Case 1:20-cv-00833-PAE Document 24-1 Filed 08/05/20 Page 6 of 6
operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
--
Danielle Ivory
The New York Times
Office: 212-556-1596
Cell: 917-280-2607
Fax: 646-349-2536
Signal encrypted chat: 917-280-2607
EFTA00015400

=== Page 41 ===
Case 1:20-cv-00833-PAE Document 24-2 Filed 08/05/20 Page 1 of 5
Attachment 2
EFTA00015401

=== Page 42 ===
Page 1 of 4
Case 1:20-cv-00833-PAE Document 24-2 Filed 08/05/20 Page 2 of 5
OGC Electronic Freedom of Information - NYT FOIA request - -- BOP #2, filed 8/13/19
From:
"Ivory, Danielle" <danielle.ivory@nytimes.com>
To:
<OGC_EFOIA@bop.gov>
Date:
8/13/2019 5:00 PM
Subject: NYT FOIA request -- BOP #2, filed 8/13/19
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of any help in explaining this
or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone: 212-556-1596
Mobile phone: 917-280-2607
Email: danielle.ivory@nytimes.com
Aug. 13, 2019
Bureau of Prisons
OGC_EFOIA@BOP.GOV
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise
produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed
forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs,
EFTA00015402

=== Page 43 ===
Page 2 of 4
Case 1:20-cv-00833-PAE Document 24-2 Filed 08/05/20 Page 3 of 5
minutes of meetings, records of meetings in any form, and any other compilation of data from which
information can be obtained. All of the foregoing are included in this request if they are in the
possession of or otherwise under the New York Times requests for Records of the following type in the
possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of
(or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"):
(1) All video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide
attempt.
(2) All BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt.
(3) All BOP documents, including email correspondence and meeting minutes, pertaining to the
decision to remove Jeffrey Epstein from suicide watch.
(4) All BOP special investigation reports mentioning Jeffrey Epstein.
(5) All BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein.
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the
BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau. For this
request, records generated by BOP employees based in New York, Texas, and in Washington, DC,
should be searched.
I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I
request the Records to inform the public about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending investigations, you may not assert
Exemption 7(A) without conducting a document-by-document review to determine whether release of
the records would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation
to conduct record-level reviews at the administrative level before refusing to produce records contained
in its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to
withhold records only when their release would work some foreseeable or is prohibited by law, not just
because they may technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them only if their disclosure
EFTA00015403

=== Page 44 ===
Page 3 of 4
Case 1:20-cv-00833-PAE Document 24-2 Filed 08/05/20 Page 4 of 5
would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5
U.S.C 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from
release of the information being withheld, consider partial disclosure of the information, take reasonable
steps to segregate and release nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business days. This request is
segregable, and your agency may not withhold entire records because of one section that you believe
is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records
from disclosure, you must specify in a written response the factual and legal basis for withholding any
part of the Records.
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C.
$ 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion
of the request needs to be processed by another agency, please inform me which agency that is and
whether it has provided you with an estimated date of completion.
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer files in the same format as
they are currently maintained at the agency, pursuant to Burka V. Dept. of Health & Human Svcs., 87
F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing
hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. $
552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records.
FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the
public's "right to be informed about what their government is up to." U.S. Dep't of Justice V. Reporters
Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted).
In order to provide public access to this information, FOIA's fee waiver provision requires "[d]ocuments
shall be furnished without any charge or at a [reduced] charge
disclosure of the information is in the
public interest because it is likely to contribute significantly to public understanding of the operations or
activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. $
EFTA00015404

=== Page 45 ===
Page 4 of 4
Case 1:20-cv-00833-PAE Document 24-2 Filed 08/05/20 Page 5 of 5
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who
was accused of sexually abusing scores of women and underage girls. Not only has a person died in
federal custody, but the death has generated multiple conspiracy theories implicating government
works at the highest levels and taxpayer money. Disclosure of the records request is in the public
interest because disclosure is likely to contribute significantly to the understanding of the operations or
activities of the government. In addition, as one of the largest circulation newspapers in the United
States, The New York Times plays an important role in sharing information with the public and helping
the public understand how the federal government works. Disclosure of the records is not primarily in
the commercial interest of myself or The New York Times but is intended to facilitate reporting on the
operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
Danielle Ivory
The New York Times
Office: 212-556-1596
Cell: 917-280-2607
Fax: 646-349-2536
Signal encrypted chat: 917-280-2607
EFTA00015405

=== Page 46 ===
Case 1:20-cv-00833-PAE Document 24-3 Filed 08/05/20 Page 1 of 3
Attachment 3
EFTA00015406

=== Page 47 ===
Case 1:20-cv-00833-PAE Document 24-3 Filed 08/05/20 Page 2 of 3
DIFFERTMENT
THE BUREAU THE
U.S. Department of Justice
Federal Bureau of Prisons
Central Office
320 First St., NW
Washington, DC 20534
September 23, 2019
Danielle Ivory
The New York Times
620 Eighth Avenuse
New York, NY 10018
danielle.ivory@nytimes.com
Request Number: 2019-05665
Dear Ms. Ivory:
This is in response to the above referenced Freedom of Information Act (FOIA) request,
which we received on August 13, 2019. Specifically, you request various documents
regarding inmate Jeffrey Epstein.
After a thorough review of your request, we have determined that any records
responsive to your request are categorically exempt from disclosure. Accordingly, this
Office is not required to conduct a search for the requested records. Pursuant to the
Freedom of Information Act, 5 U.S.C. § 552, records are withheld in full from disclosure
to you under the following exemptions:
(b)(5) - inter- or intra-agency correspondence which would not be available to a party
other than a party in litigation with the agency
(b)(6) - constitutes a clearly unwarranted invasion of personal privacy
(b)(7)(A) - could reasonably be expected to interfere with law enforcement proceedings
(b)(7)(C) - constitutes an unwarranted invasion of personal privacy
(b)(7)(E) - discloses investigative techniques and procedures
(b)(7)(F) - could reasonably be expected to endanger the life or physical safety of any
individual
Please note, exemption (b)(7)(A) is a temporary exemption utilized to protect active and
on-going law enforcement proceedings. Because of its temporary nature, you may wish
to consider refiling your request for records in the future. Should you chose to refile your
request, the status of law enforcement proceedings will be reevaluated and a
determination made at that time as to the continued applicability of exemption (b)(7)(A).
If you have questions about this response please feel free to contact me at
kchristenson@bop.gov or the Federal Bureau of Prisons' (BOP) FOIA Public Liaison,
EFTA00015407

=== Page 48 ===
Case 1:20-cv-00833-PAE Document 24-3 Filed 08/05/20 Page 3 of 3
Mr. C. Darnell Stroble at (202) 616-7750 or 320 First Street NW, Suite 936, Washington
DC 20534 or ogc_efoia@bop.gov.
Additionally, you may contact the Office of Government Information Services (OGIS) at
the National Archives and Records Administration to inquire about the FOIA mediation
services they offer. The contact information for OGIS is as follows: Office of
Government Information Services National Archives and Records Administration, Room
2510, 8601 Adelphi Road, College Park, Maryland 20740-6001; telephone at (202) 741-
5770; toll free at (877) 684-6448; or facsimile at (202) 741-5769.
If you are not satisfied with my response to this request, you may administratively
appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Sixth Floor, 441 G Street NW, Washington, DC 20001. Your
appeal must be postmarked within 90 days of the date of my response to your request.
If you submit your appeal by mail, both the letter and the envelope should be clearly
marked "Freedom of Information Act Appeal."
Sincerely,
Christmason
Eugene E. Baime
Supervisory Attorney
EFTA00015408

=== Page 49 ===
Case 1:20-cv-00833-PAE Document 24-4 Filed 08/05/20 Page 1 of 3
Attachment 4
EFTA00015409

=== Page 50 ===
Case 1:20-cv-00833-PAE Document 24-4 Filed 08/05/20 Page 2 of 3
U.S. Department of Justice
Office of Information Policy
Suite 11050
1425 New York Avenue, NW
Washington, DC 20530-0001
Telephone: (202) 514-3642
Alexandra Perloff-Giles, Esq.
The New York Times Company
620 8th Avenue
Re:
Appeal No. DOJ-AP-2020-000123
New York, NY 10018
Request No. 2019-05665
aperloffgiles@nytimes.com
CDT:CCG
VIA: Email
Dear Alexandra Perloff-Giles:
You appealed from the action of the Federal Bureau of Prisons (BOP) on your Freedom
of Information Act request for access to records concerning specific documents related to Jeffery
Epstein and his death at Metropolitan Correctional Center on August 10, 2019. I note that your
appeal concerns the withholdings made by BOP.
After carefully considering your appeal, I am affirming, on partly modified grounds,
BOP's action on your request. The FOIA provides for disclosure of many agency records. At
the same time, Congress included in the FOIA nine exemptions from disclosure that provide
protection for important interests such as personal privacy, privileged communications, and
certain law enforcement activities. BOP properly withheld this information in full because it is
protected from disclosure under the FOIA pursuant to 5 U.S.C. $ 552(b)(7)(A) and it is
reasonably foreseeable that disclosure of this information would harm the interests protected by
this provision. This provision concerns records or information compiled for law enforcement
purposes the release of which could reasonably be expected to interfere with enforcement
proceedings.
I
Please be advised that this Office's decision was made only after a full review of this
matter. Your appeal was assigned to an attorney with this Office who thoroughly reviewed and
analyzed your appeal, your underlying request, and the action of the BOP in response to your
request.
If you are dissatisfied with my action on your appeal, the FOIA permits you to file a
lawsuit in federal district court in accordance with 5 U.S.C. § 552(a)(4)(B).
I Please be advised that since this Office determined that records responsive to your request were properly withheld
in full under Exemption 7(A), this Office did not adjudicate the applicability other exemptions cited.
EFTA00015410

=== Page 51 ===
Case 1:20-cv-00833-PAE Document 24-4 Filed 08/05/20 Page 3 of 3
- 2 -
For your information, the Office of Government Information Services (OGIS) offers
mediation services to resolve disputes between FOIA requesters and Federal agencies as a non-
exclusive alternative to litigation. Using OGIS services does not affect your right to pursue
litigation. The contact information for OGIS is as follows: Office of Government Information
Services, National Archives and Records Administration, Room 2510, 8601 Adelphi Road,
College Park, Maryland 20740-6001; email at ogis@nara.gov; telephone at 202-741-5770; toll
free at 1-877-684-6448; or facsimile at 202-741-5769. If you have any questions regarding the
action this Office has taken on your appeal, you may contact this Office's FOIA Public Liaison
for your appeal. Specifically, you may speak with the undersigned agency official by calling
(202) 514-3642.
Sincerely,
3/5/2020
M.H.M
M
X
Matthew W. Hurd
Acting Chief, Administrative Appeals Staff
Signed by: MATTHEW HURD
EFTA00015411

=== Page 52 ===
Case 1:20-cv-00833-PAE Document 24-5 Filed 08/05/20 Page 1 of 4
Attachment 5
EFTA00015412

=== Page 53 ===
Case 1:20-cv-00833-PAE Document 24-5 Filed 08/05/20 Page 2 of 4
From:
"Ivory, Danielle" <danielle.ivory@nytimes.com>
To:
<OGC EFOIA@bop.gov>
Date:
12/12/2019 3:05 PM
Subject:
NYT FOIA to BOP, Epstein logs
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of
any help in explaining this or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone: 212-556-1596
Mobile phone: 917-280-2607
Email: danielle.ivory@nytimes.com
Dec. 12, 2019
Bureau of Prisons
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten,
typed, electronic or otherwise produced, reproduced or stored), letters,
memoranda, correspondence, notes, applications, completed forms, studies,
reports, reviews, telephone conversations, faxes, emails, documents,
photographs, minutes of meetings, records of meetings in any form, and any
other compilation of data from which information can be obtained. All of
the foregoing are included in this request if they are in the possession of
or otherwise under the New York Times requests for Records of the following
type in the possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq
("FOIA"), I request copies of (or access to) documents about Jeffrey
Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10,
2019, specifically (hereafter described as "the records"):
(1) The full log of Mr. Epstein's phone calls to and from the MCC.
(2) All email correspondence to and from Mr. Epstein while he was at the
MCC (including any correspondence through the Corrlinks system or any other
email system he had access to.)
EFTA00015413

=== Page 54 ===
Case 1:20-cv-00833-PAE Document 24-5 Filed 08/05/20 Page 3 of 4
(3) The full log of people who visited Mr. Epstein while he was at the MCC
and when they visited.
(4) The full list of people that Mr. Epstein had requested to be on his
approved visitor list.
(5) The full list of people that Mr. Epstein had requested to be on his
approved email correspondence list.
(6) The full list of people that Mr. Epstein had requested to be on his
approved call list.
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey
Epstein is listed in the BOP system, so identifying the correct Jeffrey
Epstein should not be a problem for the bureau. For this request, records
generated by BOP employees based in New York, Texas, and in Washington, DC,
should be searched.
I am a reporter for The New York Times, an accredited and recognized
newsgathering organization. I request the Records to inform the public
about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending
investigations, you may not assert Exemption 7(A) without conducting a
document-by-document review to determine whether release of the records
would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently
"remind[ed] the FBI of its obligation to conduct record-level reviews at
the administrative level before refusing to produce records contained in
its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234
(D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing
federal agencies to withhold records only when their release would work
some foreseeable or is prohibited by law, not just because they may
technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them
only if their disclosure would actually harm the interest protected by the
exemption, or if it is prohibited by some other law. 5 U.S.C 552(a)(8). The
agency does need to identify what reasonably foreseeable harm would flow
from release of the information being withheld, consider partial disclosure
of the information, take reasonable steps to segregate and release
nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business
days. This request is segregable, and your agency may not withhold entire
records because of one section that you believe is exempt from disclosure.
Under federal law, if you choose to withhold any such parts of the records
from disclosure, you must specify in a written response the factual and
legal basis for withholding any part of the Records.
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date
of completion. See 5 U.S.C. $ 552(a)(7)(B)(ii). If the estimated date of
completion is being significantly delayed because of a portion of the
request needs to be processed by another agency, please inform me which
agency that is and whether it has provided you with an estimated date of
completion.
EFTA00015414

=== Page 55 ===
Case 1:20-cv-00833-PAE Document 24-5 Filed 08/05/20 Page 4 of 4
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer
files in the same format as they are currently maintained at the agency,
pursuant to Burka V. Dept. of Health & Human Svcs., 87 F.3d 508 (D.C. Cir.
1996). As you know, providing documents electronically is cheaper than
mailing hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this
request as provided by 5 U.S.C. $ 552(a)(4)(A)(iii). FOIA was designed to
provide citizens a broad right to access government records. FOIA's basic
purpose is to "open agency action to the light of public scrutiny," with a
focus on the public's "right to be informed about what their government is
up to." U.S. Dep't of Justice V. Reporters Comm. For Freedom of Press, 489
U.S. 749, 773-74 (1989) (internal quotation and citations omitted). In
order to provide public access to this information, FOIA's fee waiver
provision requires "[d]ocuments shall be furnished without any charge or at
a
[reduced] charge disclosure of the information is in the public
interest because it is likely to contribute significantly to public
understanding of the operations or activities of the government and is not
primarily in the commercial interest of the requester." 5 U.S.C. §
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and
death of Jeffrey Epstein, who was accused of sexually abusing scores of
women and underage girls. Not only has a person died in federal custody,
but the death has generated multiple theories implicating government works
at the highest levels and taxpayer money. Disclosure of the records request
is in the public interest because disclosure is likely to contribute
significantly to the understanding of the operations or activities of the
government. In addition, as one of the largest circulation newspapers in
the United States, The New York Times plays an important role in sharing
information with the public and helping the public understand how the
federal government works. Disclosure of the records is not primarily in
the commercial interest of myself or The New York Times but is intended to
facilitate reporting on the operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
Danielle Ivory
The New York Times
Office: 212-556-1596
Cell: 917-280-2607
Fax: 646-349-2536
Signal encrypted chat: 917-280-2607
EFTA00015415

=== Page 56 ===
Case 1:20-cv-00833-PAE Document 24-6 Filed 08/05/20 Page 1 of 5
Attachment 6
EFTA00015416

=== Page 57 ===
Page 1 of 4
Case 1:20-cv-00833-PAE Document 24-6 Filed 08/05/20 Page 2 of 5
OGC Electronic Freedom of Information - New York Times FOIA to BOP (Phone recording)
From:
"Ivory, Danielle" <danielle.ivory@nytimes.com>
To:
<OGC_EFOIA@bop.gov>
Date:
1/2/2020 9:10 AM
Subject: New York Times FOIA to BOP (Phone recording)
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of any help in explaining this
or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone: 212-556-1596
Mobile phone: 917-280-2607
Email: danielle.ivory@nytimes.com
Jan. 2, 2020
Bureau of Prison
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise
produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed
forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs,
minutes of meetings, records of meetings in any form, and any other compilation of data from which
1/9/2020
EFTA00015417

=== Page 58 ===
Page 2 of 4
Case 1:20-cv-00833-PAE Document 24-6 Filed 08/05/20 Page 3 of 5
information can be obtained. All of the foregoing are included in this request if they are in the
possession of or otherwise under the New York Times requests for Records of the following type in the
possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of
(or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"):
(1) The full recordings of the last three phone conversations that Mr. Epstein had.
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the
BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau. For this
request, records generated by BOP employees based in New York, Texas, and in Washington, DC,
should be searched.
I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I
request the Records to inform the public about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending investigations, you may not assert
Exemption 7(A) without conducting a document-by-document review to determine whether release of
the records would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation
to conduct record-level reviews at the administrative level before refusing to produce records contained
in its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to
withhold records only when their release would work some foreseeable or is prohibited by law, not just
because they may technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them only if their disclosure
would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5
U.S.C 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from
release of the information being withheld, consider partial disclosure of the information, take reasonable
steps to segregate and release nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business days. This request is
segregable, and your agency may not withhold entire records because of one section that you believe
is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records
1/9/2020
EFTA00015418

=== Page 59 ===
Page 3 of 4
Case 1:20-cv-00833-PAE Document 24-6 Filed 08/05/20 Page 4 of 5
from disclosure, you must specify in a written response the factual and legal basis for withholding any
part of the Records.
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C.
$ 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion
of the request needs to be processed by another agency, please inform me which agency that is and
whether it has provided you with an estimated date of completion.
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer files in the same format as
they are currently maintained at the agency, pursuant to Burka V. Dept. of Health & Human Svcs., 87
F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing
hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. $
552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records.
FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the
public's "right to be informed about what their government is up to." U.S. Dep't of Justice V. Reporters
Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted).
In order to provide public access to this information, FOIA's fee waiver provision requires "[d]ocuments
shall be furnished without any charge or at a [reduced] charge
disclosure of the information is in the
public interest because it is likely to contribute significantly to public understanding of the operations or
activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. $
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who
was accused of sexually abusing scores of women and underage girls. Not only has a person died in
federal custody, but the death has generated multiple theories implicating government works at the
highest levels and taxpayer money. Disclosure of the records request is in the public interest because
disclosure is likely to contribute significantly to the understanding of the operations or activities of the
government. In addition, as one of the largest circulation newspapers in the United States, The New
York Times plays an important role in sharing information with the public and helping the public
1/9/2020
EFTA00015419

=== Page 60 ===
Page 4 of 4
Case 1:20-cv-00833-PAE Document 24-6 Filed 08/05/20 Page 5 of 5
understand how the federal government works. Disclosure of the records is not primarily in the
commercial interest of myself or The New York Times but is intended to facilitate reporting on the
operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
--
Danielle Ivory
The New York Times
Office: 212-556-1596
Cell: 917-280-2607
Fax: 646-349-2536
Signal encrypted chat: 917-280-2607
1/9/2020
EFTA00015420

=== Page 61 ===
Case 1:20-cv-00833-PAE Document 24-7 Filed 08/05/20 Page 1 of 3
Attachment 7
EFTA00015421

=== Page 62 ===
Case 1:20-cv-00833-PAE Document 24-7 Filed 08/05/20 Page 2 of 3
THE JUSTICE: AMERICA
U.S. Department of Justice
Federal Bureau of Prisons
Central Office
320 First St., NW
Washington, DC 20534
January 9, 2020
Danielle Ivory
The New York Times
620 Eighth Avenuse
New York, NY 10018
Request Number: 2020-01336
Dear Ms. Ivory:
This is in response to the above referenced Freedom of Information Act (FOIA) request.
On 01-02-2020, you submitted a FOIA request to the Federal Bureau of Prisons (BOP).
A copy of your request is attached.
After reviewing your request, the BOP determined the request should be aggregated
into one request, which is request number 2020-01336. This request was made on 12-
12-2019, which is the date you submitted the earliest request being aggregated. This
will ensure you are not disadvantaged by our action.
Department of Justice regulations provide for the aggregation of requests where "a
component reasonably believes that a requester is attempting to divide a single
request into a series of requests for the purpose of avoiding fees...." " The regulation
continues, "Components may presume that multiple requests of this type made within a
30-day period have been made in order to avoid fees." 28 C.F.R. $ 16.10(h) (2015).
BOP's decision to aggregate is based on the time both requests were filed and the
interrelation of the records sought in each request. We do not know if any fees will be
associated with this request and will inform you of any estimated fees prior to us
searching for or copying any responsive records.
Regarding your request for expedited treatment, you provided insufficient information to
support your claim regarding an urgency to inform the public. This Office cannot identify
a particular urgency to inform the public about an actual or alleged federal government
activity beyond the public's right to know about government activities generally.
You provided insufficient information to support your claim you are primarily engaged in
disseminating information that would warrant placing your request before all other
requests.
Therefore, your request will be processed in the order in which it was received.
EFTA00015422

=== Page 63 ===
Case 1:20-cv-00833-PAE Document 24-7 Filed 08/05/20 Page 3 of 3
If you would like to discuss how to make your request less burdensome, please feel free
to contact the undersigned, this office, or the Federal Bureau of Prisons' (BOP) FOIA
Public Liaison, Mr. C. Darnell Stroble at 202-616-7750, 320 First Street NW, Suite 936,
Washington DC 20534, or ogc_efoia@bop.gov.
Additionally, you may contact the Office of Government Information Services (OGIS) at
the National Archives and Records Administration to inquire about the FOIA mediation
services they offer. The contact information for OGIS is as follows: Office of
Government Information, Services, National Archives and Records Administration,
Room 2510, 8601 Adelphi Road, College Park, Maryland 20740-6001; e-mail at
ogis@nara.gov; telephone at 202-741-5770; toll free at 1-877-684-6448; or facsimile at
202-741-5769.
If you are not satisfied with my response to this request, you may administratively
appeal by writing to the Director, Office of Information Policy (OIP), United States
Department of Justice, Sixth Floor, 441 G St., NW, Washington, DC 20001, or you may
submit an appeal through OIP's FOIAonline portal by creating an account at:
https://www.foiaonline.gov/foiaonline/action/public/home Your appeal must be
postmarked or electronically transmitted within 90 days of the date of my response to
your request. If you submit your appeal by mail, both the letter and the envelope should
be clearly marked "Freedom of Information Act Appeal."
Sincerely,
S Arellano
S. Arellano, for
Eugene E. Baime, Supervisory Attorney
EFTA00015423

=== Page 64 ===
Case 1:20-cv-00833-PAE Document 24-8 Filed 08/05/20 Page 1 of 4
New York Times V. BOP, 20 Civ. 833 (SDNY)
Index of Withholdings in Full
Entry
Page count2
Description
Status
Withheld in Full (WIF) under 5 - -
Deliberative Process Privilege,
7(A); other exemptions applicable
1
2
Incident Report of Jeffrey Epstein's July 23, 2019 Apparent Suicide Attempt
in part
WIF under 5- Deliberative Process
Privilege, 7(A), 7(E); other
2
37
Psychological Reconstruction of Inmate Death
exemptions applicable in part
WIF under 7(A); other exemptions
3
23
Overtime Logs for MCC, 07/22/19-07/23/19
applicable in part
WIF under 7(A); other exemptions
4
23
Overtime Logs for MCC, 08/09/19-08/10/19
applicable in part
WIF under 7(A), except for one
page released in part; other
5
8
MCC Daily Assignment Roster for 07/22/19
exemptions applicable in part
WIF under 7(A), except for one
page released in part; other
6
7
MCC Daily Assignment Roster for 07/23/19
exemptions applicable in part
WIF under 7(A), except for one
page released in part; other
7
9
MCC Daily Assignment Roster for 08/09/19
exemptions applicable in part
WIF under 7(A), except for one
page released in part; other
8
10
MCC Daily Assignment Roster for 08/10/19
exemptions applicable in part
WIF under 7(A), 7(E); other
9
5
Inmate Investigative Report
exemptions applicable in part
WIF under 7(A), 7(E); other
10
4
MCC New York Updates
exemptions applicable in part
EFTA00015424

=== Page 65 ===
Case 1:20-cv-00833-PAE Document 24-8 Filed 08/05/20 Page 2 of 4
WIF under 5 - Deliberative
Process Privilege; other
11
2
Draft Letters
exemptions applicable in part
WIF under 5 - Deliberative
Process Privilege, 7(A), 7(E); other
12
129
Responses to Psychological Reconstruction of Inmate Death
exemptions applicable, in part
WIF under 7(A), 7(E); other
13
2
Letter to Warden dated August 14, 2019
exemptions applicable, in part
WIF under 7(A); other exemptions
14
16
Photo Sheet from 07/23/19 Apparent Suicide Attempt
applicable in part
WIF under 7(A), 7(E); other
15
7
Memo and Report from 07/23/19 Apparent Suicide Attempt (Form 583)
exemptions applicable, in part
WIF under 7(A); other exemptions
16
2
Photo Sheet from 07/23 Apparent Suicide Attempt
applicable in part
WIF under 7(A), 7(E); other
17
1
Chain of Custody Form from 07/23 Apparent Suicide Attempt
exemptions applicable, in part
WIF under 7(A), 7(E); other
18
4
Reports of 07/23 Apparent Suicide Attempt
exemptions applicable, in part
WIF under 7(A); other exemptions
19
48
Psychological records of Epstein
applicable in part
WIF under 7(A); other exemptions
20
18
Memo and Report from 08/10 Suicide (Form 583)
applicable in part
WIF under 7(A); other exemptions
21
1
Memo from Unit Manager dated 08/10/19
applicable in part
WIF under 7(A); other exemptions
22
28
Count Documents (e.g., Watch Calls, Body Alarm Records, SHU Lists)
applicable in part
WIF under 7(A); other exemptions
23
145
Count Documents (30 Minute Check Sheets)
applicable in part
WIF under 7(A); other exemptions
24
181
Count Documents (e.g., Count Slips, Rosters, Out-Count Forms)
applicable in part
WIF under 7(A); other exemptions
25
20
Investigative Documents from Suicide (e.g., Chain of Custody Forms)
applicable in part
EFTA00015425

=== Page 66 ===
Case 1:20-cv-00833-PAE Document 24-8 Filed 08/05/20 Page 3 of 4
WIF under 7(A); other exemptions
26
1
Attorney Room Visitor Log dated 07/21/2019
applicable in part
WIF under 7(A); other exemptions
27
3
Investigative Documents from Suicide
applicable in part
WIF under 7(A); other exemptions
28
4
08/10/2020 TRUINTEL Reports (including email)
applicable in part
WIF under 7(A); other exemptions
29
1
Memo to Warden dated 08/13/2019
applicable in part
WIF under 7(A); other exemptions
30
24
Count Documents
applicable in part
WIF under 7(A); other exemptions
31
5
Investigative Documents from Suicide
applicable in part
WIF under 7(A); other exemptions
32
8
TRUINTEL Reports (8/9/19-8/10/19)
applicable in part
WIF under 7(A); other exemptions
33
5
Count Documents (e.g., 30 Minute Check Sheets)
applicable in part
WIF under 7(A); other exemptions
34
4
SHU Records
applicable in part
WIF under 7(A); other exemptions
35
46
Photo Sheets from 08/10/19 Suicide
applicable in part
WIF under 7(A), 7(E); other
36
14
Photo Sheets from 07/23/19 Apparent Suicide Attempt
exemptions applicable, in part
WIF under 7(A); other exemptions
37
3
Count Documents (Inmate Assignment Charts -August 2019)
applicable in part
WIF under 7(A); other exemptions
38
27
SHU Weekly Review (08/08/2019)
applicable in part
WIF under 7(A); other exemptions
39
1
Cop Out Note
applicable in part
WIF under 7(A); other exemptions
40
2
SHU Computer Screenshots
applicable in part
WIF under 7(A); other exemptions
41
4
Psychological Reconstruction Responses
applicable in part
WIF under 7(A); other exemptions
42
1
SHU Computer Screenshots
applicable in part
EFTA00015426

=== Page 67 ===
Case 1:20-cv-00833-PAE Document 24-8 Filed 08/05/20 Page 4 of 4
WIF under 7(A); other exemptions
43
4
24-hour death report and death notification (including email)
applicable in part
WIF under 7(A); other exemptions
44
13
Office of Chief Medical Examiner Documents
applicable in part
WIF under 7(A); other exemptions
45
40
Psych Observation Logs
applicable in part
WIF under 7(A); other exemptions
46
16
Suicide Watch Logs (including one SENTRY page)
applicable in part
WIF under 7(A); other exemptions
47
1
SHU Computer Screenshots
applicable in part
WIF under 7(A); other exemptions
48
1
Memo dated 08/12/2019
applicable in part
WIF under 7(A); other exemptions
49
7
Lieutenant's Log (08/09-08/10)
applicable in part
WIF under 7(A); other exemptions
50
1
Scan of sign
applicable in part
WIF under 7(A); other exemptions
51
2
Memo dated 08/10/2019
applicable in part
Approximately
Emails pertaining to Epstein's July 23, 2019 apparent suicide attempt,
WIF under 7(A); other exemptions
52
986
Epstein's mental health, and Epstein's incarceration prior to his suicide.
applicable in part
Emails relating to Epstein's death, investigations into Epstein's death, the
Approximately
circumstances of his suicide, and the Bureau of Prisons's response to
WIF under 7(A); other exemptions
53
1,162
Epstein's death
applicable in part
WIF under 5 - Attorney-Client
Emails between BOP Employees and Assistant United States Attorneys in the
Privilege; other exemptions
54
56
United State's Attorneys Office for the Southern District of New York
applicable in part
EFTA00015427


