# docs_fts_content

c1: EFTA00019337
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019337.pdf
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: EMS AUDIO: Reveals Jeffrey Epstein DEAD FOR HOURS While on Suicide Watch
Date: Sun, 11 Aug 2019 04:55:58 +0000
https://thedcpatriot.com/ems-audio-reveals-jeffrey-epstein-dead-for-hours-while-on-suicide-watch/
EFTA00019337


c1: EFTA00019609
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019609.pdf
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=== Page 1 ===
December 9, 2009
MEMO TO FILE
RE:
On December 4, 2009, deposition of
was taken.
took the deposition, and
also attended.
attended on behalf of
was the videographer.
said she met with the state attorney one time. She said in that meeting, the victims
advocate was there, which was a black lady. A man and a woman, she thought was from the
state attorney's office, but she couldn't tell if they were from the state or federal government,
and a lady from the FBI, who was white.
She did not have a lawyer or anyone there on her behalf.
She also met with somebody from the FBI that came to her house, which was the trailer.
This occurred at
and her brother and mother and
were there. The
,
FBI people that came were a man and a woman.
They tape recorded her second meeting.
She said she felt Dr.
was an idiot.
She said
has seen her since she was 13.
Dr.
also saw her.
She went to court with a public defender. She did argue with
It was upsetting to her.
She saw Dr.
in Orlando and met Dr.
through her attorneys. She does not trust men
over 40.
EFTA00019609

=== Page 2 ===
She said she's been a waitress and a people person.
She went out many times.
Paid by the hour. She was paid in cash by the person she was escorting. She did not know how
much was negotiated ahead of time, but this was done by the owner. She then gave the money
to the driver and got her cut. She never filed taxes, and she used the stage name of
She has no records of when she went there.
she was also paid
cash and has no records.
She went to dinner, dancing, and events with these people. She did enjoy her time out, but she
would not do any sexual acts.
She's had ecstasy and crystal meth. She does do oxycodin.
Dr.
prescribed them to her in
She hasn't seen him in over a year. She
started seeing him after
She still has neck and back pain. She has hypodermic needles, which she said she got from a
pharmacy. She would take the roxy as a pill and then shoot them up.
She has snorted heroin one time, and she also shot up cocaine probably at 18. She first started
using cocaine after Epstein.
Epstein never told her to take drugs, but she used the money he gave her to buy drugs. Epstein
knew she took drugs. She would go to the bathroom and take the drugs. She did cocaine
powder. She never got alcohol from him and never had intercourse with Epstein.
What she would do is
while he
She was
She doesn't know by who.
brought her originally, and she stated that
has now disappeared.
Epstein did call her on at least 2 occasions when she talked to him.
Otherwise,
or one of the other employees would call her to set up the appointment.
Epstein called her and gave her concert tickets and also lingerie.
She called Epstein probably more than 4 times. She talked to
or Maxwell and also a
cook.
EFTA00019610

=== Page 3 ===
The last time she saw him was sometime in August of 2003, and she first saw him in May of
2002.
She said Epstein gave her a book called Massage for Dummies.
He said he would pay for massage school for her. She decided to go. She did tell him she was
going to be 14.
She was paid twice $200 and after that $300. She enjoyed getting the money.
The first time she was there, she was asked to take off her shirt. She told him she did not want
to, but he told her he would give her extra money.
The second time she was in her bra and underwear and was asked to get naked several times.
On the third time, she took off her bra, and Epstein told her she didn't need to be naked.
was a friend of
guy friend, who was
ask her
.
to go that same day, and they went the same day to see Epstein. Epstein gave her his phone
number, and she went for several months before she brought anyone else with her. She did have
another girl perform
on her.
She said she was a very pretty girl. She never saw her before. Epstein went in the shower.
Told her to get naked. She said she did
when she was 12, who was
They met in school. They had a sexual and friendship relationship. She did
have a video make with her boyfriend. She did not do any photos other than with Epstein.
When Epstein took the pictures, it was with a digital camera, and she said it was a large camera
and also a smaller one.
took the pictures, and they were done all through the house. She
was totally nude. The video she did was with
, and they used a condom.
She brought
and
with
to Epstein.
Epstein asked her to bring young girls, and she told
that Epstein would
She never felt she was in danger.
She went to Georgia to live with
father and aunt and uncle.
She did not use crack in 2003 while sh
EFTA00019611

=== Page 4 ===
She started doing drugs again in about January of 2005.
She had secrets she kept from
about Epstein, and she kept telling
she was just
cleaning house there. She feels that once she told
what was really happening, that was
one of the reasons they broke up.
The problem now is she does not like older men and does not trust them.
They questioned her extensively regarding her escort services. She confirmed that they were
men of various ages, and it was more than 25, but less than 50 people that she went out with.
The one thing she told them is that they could not do crack, and she would not have sex with
them.
All the men were older than her. She felt she never needed any mental treatment as a result of
the escort service.
She did not work in topless bars, except one night when she went as a stripper. She did it for 3
hours.
It was after she had met with Epstein, and she left as
she felt degraded.
She did not have normal sex with
after Epstein. She did not have sex 2 times a day after
Epstein, but did have it before Epstein. She would have sex once or twice a week after being
with Epstein.
She also felt she did not have sex with
as often as he wanted.
She felt she never complained to her mom about
is with
and she has signed her rights away. She sees
once a month
when her grandmother brings her to Florida.
did slap her in a restaurant.
did hold a gun to her head.
was dating
while she was seeing Epstein.
apologized that she
had seen
, but after that, she was never friends with
again.
She had
checks with
EFTA00019612

=== Page 5 ===
Dr.
said that
had held a gun to her head for an hour. She said it wasn't for an hour.
That they were simply out there for an hour.
also held her head under a canal in West
Palm Beach.
She did tell Epstein about the drowning incident, and he told her she needs to leave
is now in jail, because he beat up the
Allegedly
had told Epstein that she and her mom had sexual flings together. When they
were talking about it, she left the room.
She did not share her $100 with
but she did share it with
,
when she got it for
bringing her in.
The first time
came, they both
At 18, she did try crack with some friends, but she does not know who provided it.
She feels she lost her boyfriend due to Epstein, and that
had been very upset since he
found what was going on.
She never told her mother that she used crack.
She first used Ecstasy after being with Epstein.
She thinks there might be an
as she felt she was 14 when she first saw
Epstein, not 15.
She used heroin when she was 21 at
house when someone provided it to her.
told her to do it, and she did, but she did not want to. She used crystal meth when she was 18
first, and it was given to her by someone. She did it, because she thought it was something new.
She has been detoxed at least 2 times. The first time was in 2009 in her living room and went to
CARP the second time in 2009. Both times, it was from roxys. She said she went on to roxys
because of back pain.
She went through the 7th grade, and she believes she attended
In 8th grade, she was
told she was too sexually developed and was asked to leave. As she was now 16, she didn't
have to stay in school so she was not truant.
Spent most of her time watching TV.
She did throw a knife at her brother when he allegedly tried to kill her cat.
She really didn't have much information about he
EFTA00019613

=== Page 6 ===
The deposition ended at 5:00 PM.
EFTA00019614


c1: EFTA00018098
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018098.pdf
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=== Page 1 ===
From:
To:
Subject: RE: Discovery Letter in Maxwell
Date: Tue, 03 Nov 2020 21:50:33 +0000
Attachments: 2020-10-07_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_(FINAL).pdf
Assuming that's what you want it's attached. If not, just let me know and I'll try to get you what you're looking for.
From:
Sent: Tuesday, November 3, 2020 4:49 PM
To:
Subject: RE: Discovery Letter in Maxwell
Sure - which one? The one in which we outlined the various materials we planned to gather from other offices?
From:
Sent: Tuesday, November 3, 2020 2:15 PM
To:
Subject: Discovery Letter in Maxwell
Can you send me the final as filed? I want to refer to it as an example to some other AUSAs. Tx
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00018098


c1: EFTA00019446
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019446.pdf
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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: November 19, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No:
20 Cr. 330 (AJN)
USAO No:
2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must
exactly match the witness's driver's license or other travel ID or TSA will not permit the
witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date:
Witness Needed to Appear for:
Trial (X)
Date:
Grand Jury ( )
Date:
Trial/GJ Prep (X)
Date:
Estimated Dates Witness will Arrive:
Depart:
Is the person a Fact Witness and not an Expert Witness?
(Yes/No): Yes
Current Federal Civilian or Military Employee?
(Yes/No): No
Is the Witness Facing Criminal Charges?
(Yes/No): No
Does the Witness Reside Outside the Continental United States?
(Yes/No): No
Is this Witness a Victim-Witness?
(Yes/No): Yes
Hotel Required?
(Yes/No): Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No): No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
rev. 2019.11.19
EFTA00019446

=== Page 2 ===
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00019447


c1: EFTA00019834
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019834.pdf
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=== Page 1 ===
Event: Tentative: TC with Reid Weingarten re Epstein
Start Date: 2019-11-19 21:30:00 +0000
End Date: 2019-11-19 22:00:00 +0000
Location: RD's office
Class: X-PERSONAL
Comment:
Date Created: 2019-11-19 21:15:45 +0000
Date Modified: 2019-11-19 21:15:45 +0000
Priority: 5
DTSTAMP: 2019-11-19 20:17:54 +0000
Attendee:
(USANYS)
EFTA00019834


c1: EFTA00017870
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017870.pdf
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Epstein
Date: Sat, 16 Nov 2019 23:34:19 +0000
We need to set up a time with team to discuss a few things, including the LA trip, progress on pros memos, and
the potential estate investigation including the
proffer and Civ div involvement. I could conceivably do
late Monday like 5-530 ish. I could also possibly do 3. I know you're then out Tuesday for the closing, but
Wednesday is pretty open.
Sent from my iPhone
EFTA00017870


c1: EFTA00019330
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019330.pdf
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=== Page 1 ===
From:
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Meeting tomorrow
Date: Mon, 12 Aug 2019 18:46:17 +0000
That works, thanks very much.
Original Message
From:
(USANYS)
Sent: Monday, August 12, 2019 2:37 PM
To:
(USANYS)
Cc:
)
i
Subject: RE: Meeting tomorrow
Definitely. How about 10?
Original Message
From:
Sent: Monday, August 12, 2019 2:35 PM
To:
(USANYS)
i
(USANYS)
Cc:
)
i
Subject: Meeting tomorrow
,
Would you be available to meet to discuss next steps in the Epstein case tomorrow either before 11 or after 2?
Thanks,
EFTA00019330


c1: EFTA00018902
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018902.pdf
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=== Page 1 ===
Event: Brass Meeting on Epstein
Start Date: 2019-12-10 18:00:00 +0000
End Date: 2019-12-10 19:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-12-07 07:53:28 +0000
Date Modified: 2019-12-07 07:53:28 +0000
Priority: 5
DTSTAMP: 2019-12-06 23:05:27 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00018902


c1: EFTA00019910
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019910.pdf
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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
)"
X
"
)"
Cc:
)"
Subject: RE: flight records
Date: Thu, 12 Dec 2019 01:29:33 +0000
Attachments: Rodgers,_David_Transcript_(06-03-16).pdf;, Rodgers_Exhibit_01.pdf
No problem-- here's the deposition transcript and exhibit (the set of flight records).
Original Message
From:
(NY) (FBI)
Sent: Wednesday, December 11, 2019 7:16 PM
To:
)
i
)
Cc:
Subject: flight records
Hey all,
If you don't mind sending those flight records again, I'd appreciate it. I can't seem to find it in my emails. No
rush, just when you have a chance.
Thanks!
Special Agent
FBI New York
C:
O:
EFTA00019910


c1: EFTA00020341
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020341.pdf
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Bail Statement
Date: Wed, 17 Jul 2019 22:34:07 +0000
What's their concern?
From:
Sent: Wednesday, July 17, 2019 5:17 PM
To:
Cc:
Subject: Epstein Bail Statement
We conferred with
and
they expressed misgivings about making any statements regarding detention and at
this point, we agree.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
Press Office:
EFTA00020341


c1: EFTA00017769
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017769.pdf
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=== Page 1 ===
From: Louise Scott
To:
)"
Cc:
)"
)"
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Date: Tue, 07 Jul 2020 14:50:39 +0000
Inline-Images: image0bcff8.PNG; image3f6570.PNG
Hi
Many thanks for confirming.
Can this call please take place via BlueJeans? It is a video conferencing application that we are using and I will send
through an invite which will enable you to connect to the meeting.
Could I just confirm the attendees please -
and yousrselfqa ?
Kyle Philips another partner of the firm will also be in attendance for the call.
I look forward to hearing.
Kind regards
Louise
Louise Scott
Executive Assistant
D:
Click here for information relating to Covid-19 business impacts
Fieldfisher Logo
f
in
From:
Sent: Tuesday, July 7, 2020 3:01 PM
To: Louise Scott
Cc: Jill Greenfield
is
Subject: Re: Epstein investigation [FFW-DOCS.FID6003375]
Louise,
Thanks very much, that time works for us. What is the best number to reach Jill at that time- or is there a
conference line she would prefer to use?
Thanks,
Sent from my iPhone
EFTA00017769

=== Page 2 ===
On Jul 7, 2020, at 7:57 AM, Louise Scott
wrote:
Dear
Many thanks for your email.
Jill would be free to speak on Thursday at 2pm (UK time) - would this be suitable for you all?
Kind regards
Louise
Louise Scott
Executive Assistant
D:
Click here for information relating to Covid-19 business impacts
Fieldfisher Logo
<image682813.PNG> <imageea0e95.PNG>
From:
Sent: Monday, July 6, 2020 11:50 PM
To: Jill Greenfield
Cc: Louise Scott
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi Jill,
I hope you're doing well. We continue to be interested in speaking with your client in connection with our investigation,
and we think it would be helpful to check in and discuss how best to proceed in light of the pandemic. Are you available
for a call this week? We are generally available, so if you could please let us know what times would work for you for a
call, that would be great.
Thanks very much,
Assistant United States Attorney
Southern District of New York
From:
Sent: Wednesday, March 11, 2020 9:46 PM
To: Jill Greenfield
Cc: Louise Scott
i
EFTA00017770

=== Page 3 ===
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Following up on the below, given the development of the virus pandemic over the past week, any foreign travel for us is
completely shut down. We certainly will plan to come to the U.K. whenever we are permitted, but in the interim this
makes it even more valuable to get even a summary of what your client would expect to convey to us. Would it be
possible to set up a call for later this week or sometime next week? And profound apologies for the inconvenience in
changing plans, we certainly don't want to cause additional stress or anxiety to your client, the circumstances are just
completely beyond our control.
thank you,
From:
)
Sent: Thursday, March 05, 2020 13:13
To: Jill Greenfield
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Just to clarify, would it be possible for you to provide us even a very general or high-level summary of what she has told
you? We ordinarily don't go into interviews completely blind when witnesses have counsel - and the Weinstein
investigation had a great number of problems that we have been able to avoid. And separately, we'll of course keep you
updated on our approval process as well.
thanks again,
From: Jill Greenfield
Sent: Thursday, March 05, 2020 04:20
To:
Cc: Louise Scott
is
is
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Thanks
I am afraid that an attorney proffer will not be possible. I have been working with the DA in New York on the Weinstein
case and have simply offered up my clients to questions which has worked well.
I am of course happy to speak over the phone but it seems to me that you are better off getting the information first hand.
If you wish it may be sensible for you to initially have a call with my client?
My client has made a complaint to the Met police regarding a sexual assault by Jeffrey Epstein whilst in London and in
the employment of G Maxwell. Apart from the complaint itself, no further information has been provided to the police.
I appreciate the issue re coronavirus of course.
Kind regards,
Jill
EFTA00017771

=== Page 4 ===
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Wednesday, March 4, 2020 5:04 PM
To: Jill Greenfield
Cc: Louise Scott
>;
>;
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
That's great, thank you for letting us know, and we'll check on that right away and get back to you as soon as possible.
The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government
international travel being prevented due to the coronavirus situation, but we'll talk to the relevant people here
immediately.
One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here - and we
talked about this on the phone as well - would be to get an attorney proffer about your understanding of generally what
information you expect your client will convey on the subjects we've spoken about? We completely understand that it's
best to have her tell her story directly to us, but in terms of our preparation it's often very useful for both us and the
witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a call to have
that discussion? We could do as soon as tomorrow or Friday, or also next week.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, March 04, 2020 11:46
To:
Cc: Louise Scott
is
>;
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi
There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know please?
Kind regards
Jill
Jill Greenfield
Partner
D:
EFTA00017772

=== Page 5 ===
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Tuesday, March 3, 2020 11:17 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
)
is
Subject: RE: Epstein investigation
Jill,
We wanted to quickly follow up since I think you and I last spoke a little over a week ago-understand if you are still
discussing with your client, just wanted to check in, and we're happy to provide any additional information that might be
useful, as always.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 17:09
To:
(USANYS)
Cc: Kyle Phillips
>; Louise Scott
is
(USANYS)
is
(USANYS)
Subject: Re: Epstein investigation
Thanks
Understood
I will call tomorrow
Regards
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 22 Feb 2020, at 21:51,
(USANYS)
wrote:
Jill,
EFTA00017773

=== Page 6 ===
No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful
that your client is open to speaking with us.
On your questions, we are certainly fine with the first two questions / requests - we're happy to meet with you and
your client in an initial conversation, during which we can do the kind of introductions and explanations we've done
with you (and that we do with all victim witnesses we meet), including answering any questions to the best of our
ability, and then to take a break and have a more substantive discussion later on.
Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include
individuals in addition to the witness and counsel in an interview-what does sometimes work is for someone who is
providing support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness
wants to speak with that person, which would of course be totally fine in this instance. Or if he represents her in his
capacity as an attorney then he of course could be in the interview in that role (with the only caveat that we would just
want to confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to
pay for third parties (including counsel) to travel in connection with witness interviews, though - if it's preferable, we
certainly could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it
easier for the friend to be present? And we're happy to discuss any of this further by email or phone if that's useful -
l'll be at my desk for the next several hours and most of tomorrow, at
or we could also set a time to
chat, whatever would be helpful.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 13:55
To:
(USANYS)
Cc: Kyle Phillips
>; Louise Scott
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein investigation
Hello
Apologies for the slight delay. My client is willing to help but asks the following:
That there be a morning meeting at which introductions with a discussion as to the investigation and my clients
involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist.
In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
That a friend of hers be allowed to be present as well. However that friend is based in the US and would need
to be flown over to London. He is a US lawyer.
Perhaps you could let me know if this is possible?
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
EFTA00017774

=== Page 7 ===
<image001.jpg>
From:
(USANYS)
Sent: Saturday, February 15, 2020 7:08 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
;
(USANYS)
is
(USANYS)
Subject: RE: Epstein investigation
Understood - thanks very much.
From: Jill Greenfield
Sent: Saturday, February 15, 2020 07:22
To:
(USANYS)
Cc: Kyle Phillips
>; Louise Scott
(USANYS)
is
(USANYS)
Subject: Re: Epstein investigation
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image003.jpg>
Sent from my iPhone
On 14 Feb 2020, at 21:43,
(USANYS)
wrote:
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding
some of the additional follow-up questions you asked, and to describe in more detail for your client how we would
expect to approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the
decision to meet with us but also as to any topic or question-your client would be absolutely free to determine
what topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything
that would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell
EFTA0001775

=== Page 8 ===
her, as we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is
no problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves,
explained the status of our investigation, talked about how a discussion would proceed if your client ended up being
comfortable with that, and answered in person any questions she. We have done that previously, where we do the
talking rather than asking questions in an initial meeting, and that would of course be without any requirement for
anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are
able to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in
approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client
were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or
victimization she experienced. We wrote in our first email that we would primarily be interested in talking about
topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as
always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and
that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet
the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a
discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment
and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in
particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell
you in advance if there came a time when we thought that might be important to address, and how we could
facilitate that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure
you that every one of us has now spoken with dozens of victims in this case, and every one of us has extensive
experience more generally working with victims and working on cases involving sex offenses. We are proud of how
we have been able to work with victims in this case especially, given all of the circumstances, and we absolutely
would take the same sensitive approach with your client as we have with the many other victims in this case who
have spoken with us.
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how
our process works, and answer any questions your client has in person, we would absolutely be happy to do that
with no obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could
just address the general subject of her employment, for example. But no obligation and no pressure. We continue
to appreciate your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
Assistant U.S. Attorney
Southern District of New York
From:
(USANYS)
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein investigation
Jill,
EFTA00017776

=== Page 9 ===
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the
most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The
only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign
country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't
believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's
useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just
the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise
we're of course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI team
working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not
generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types
up those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but
I can also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have
been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of
course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any
follow-up via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
(USANYS)
Cc: Kyle Phillips
>; Louise Scott
is
(USANYS)
is
(USANYS)
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any
notes made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to
provide any comfort on this?
Many thanks
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
EFTA00017777

=== Page 10 ===
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
(USANYS)
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection
with our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to
her trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the
U.K. may be the "suspect" category-and we currently do not have reason to believe that she has committed any
U.S. federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never
spoken to her-and therefore knowing about her only through other witnesses and records-but it certainly has
been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey
Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble
believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we
hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends
not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss
particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that
would be beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein
and his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked
directly for. That would broadly include how she came to be in contact with them, the nature and scope of her
employment, any instructions she was given relating to other women or girls, and just generally her experiences
and observations in interacting with them. We ordinarily would also be interested in understanding the general
nature of the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the
specifics if she weren't comfortable with that, and in particular we often don't even broach that subject in a first
meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
Assistant U.S. Attorney
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
EFTA00017778

=== Page 11 ===
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact
the sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any
attachments for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior
agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and
regulated by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan
Lane, London EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00017779


c1: EFTA00019899
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019899.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject:
Emails
Date: Sat, 14 Dec 2019 23:12:46 +0000
Attachments: 2008-09-03_Convo_with_Epstein.pdf; 2008-09-
03_i_hear_you've_had_a_spot_of_bother.pdf;,2009-07-
22_Email_from_Jeffrey_Epstein.pdf; 2010-06-29 Meeting Jeffrey Epstein.pdf; 2010-06-
29_where_are_u.pdf;_2010-9-
2010-10-
23__Email_from_Jeffrey_Epstein.pdf; 2011-05-09_Email_to_JE_NYC.pdf; 2012-10-
3_Call_Jeffrey_Epstein.pdf
Inline-Images: image001.png
I have attached the emails provided by
Hope everyone is doing well,
EDWARDS
POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
074
Facsimile: 954-524-2822
www.epllc.com
EFTA00019899


c1: EFTA00020437
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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From: David Oscar Markus
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: U.S. V. Ghislaine Maxwell
Date: Wed, 31 Mar 2021 15:01:54 +0000
We are preparing our motion for bail in the Second Circuit and need to inform the Court of the government's
position. We intend to let the Court know that the Government's opposes Ms. Maxwell's motion and intends to
file a response. Please confirm.
Thanks,
David
--David Oscar Markus
markuslaw.com
From
(USANYS)
Sent: Thursday, March 25, 2021 7:10 PM
To: David Oscar Markus
Cc:
;
Christian Everdell; Bobbi Sternheim
);
Mark S. Cohen
Subject: RE: U.S. V. Ghislaine Maxwell
David,
Thanks for letting us know that you'll be counsel on this appeal. As an initial matter, the majority of the docket entries
you've referenced do not appear to be redacted. In any event, you may obtain these materials from defense counsel -- I've
copied them here. This case is already governed by a protective order (ECF No. 36), which is binding on all counsel.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020437

=== Page 2 ===
From: David Oscar Markus
Sent: Thursday, March 25, 2021 5:33 PM
To:
(USANYS) <
Subject: U.S. V. Ghislaine Maxwell
Good afternoon counsel:
I have been engaged to represent Ghislaine Maxwell in her appeal from the denial of her third application for
bail. In preparing this appeal, I will need access to certain unredacted documents, including docket entries 4,
18, 22, 97, 100, 103, 106, 159, 160, 165, 171, 169. Do you have any objection to me having access to these
unredacted documents? (There may be additional documents that I need, but I have not identified them as of
yet.) I'm happy to enter into a protective order with the government if you believe that is necessary. I plan on
filing the appeal next week, so I would appreciate it if you could get back to me as soon as possible.
Thank you,
David
--David Oscar Markus
markuslaw.com
EFTA00020438


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=== Page 1 ===
Florida Supreme Court Administrative Order No. AOSC20-16 allows notaries to administer oaths via remote
audio-video communication equipment. Please ask us for ways we can assist parties to appear remotely for
depositions and other proceedings due to COVID-19.
Prose Court Reporting & Legal Video Services
580 Village Boulevard, Suite 140
West Palm Beach, FL 33409
(0)
(C)
www.ProseFlorida.com
From: scheduling proseflorida.com
Sent: Friday, September 4, 2020 2:21 PM
To:
proseflorida.com
Subject: FW: 12/04/09
vs Epstein Deposition Transcript
Prose Court Reporting & Legal Video Services
580 Village Boulevard, Suite 140
West Palm Beach, FL 33409
(0)
(C)
www.ProseFlorida.com
EFTA00019607

=== Page 2 ===
From:
Sent: Wednesday, September 2, 2020 4:30 PM
To: scheduling proseflorida.com
Subject: 12/04/09
vs Epstein Deposition Transcript
Hello,
As we discussed attached is the afternoon version (Volume II) of
transcript. Can
you provide us with the morning version (Volume I)?
Thanks,
EFTA00019608


c1: EFTA00018854
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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: draft cover letter
Date: Thu, 07 Oct 2021 00:51:37 +0000
Attachments: 2021.10.XX_Maxwell_Cover_Letter_v1.5docx.docx
Here is a draft cover letter. Please feel free to edit. I left a few things highlighted that I wasn't sure about.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00018854


c1: EFTA00018381
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018381.pdf
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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: exhibit 11
Date: Fri, 19 Mar 2021 16:59:01 +0000
Attachments: Exhibit_11_(Proposed_Redactions_Per_Order).pdf
He
- yes, sent it last night!
From:
Sent: Friday, March 19, 2021 12:52 PM
To:
Subject: exhibit 11
Hi - no rush, just let me know when you think you can send me the newly redacted exhibit 11. Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00018381


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein/Maxwell briefing
Date: Wed, 10 Mar 2021 23:53:34 +0000
Attachments: 2020-08-
13,_GM,_letter_to_Judge_Nathan_re_victim_names_and_prison_privileges,_final.docx
Yep, attached.
Original Message
From:
Sent: Wednesday, March 10, 2021 6:31 PM
To:
Cc:
Subject: Epstein/Maxwell briefing
Hey,
Would you mind sending us the briefing you guys did on not identifying the victims early in Epstein/ Maxwell?
The Justice Dept in Canada is requesting a "publication ban" which would stop defense counsel from identifying
victims in the extradition case and asked us for a letter. Obviously the posture is different but it would be helpful
to see what you highlighted.
Thanks!
EFTA00018731


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c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Contact from Press regarding Jeffrey Epstein
Date: Thu, 17 Jun 2010 14:10:04 +0000
Importance: Normal
Hi
|
I received a telephone message from
She has contacted us in the
past and is currently making several calls to the FBI regarding Jeffrey Epstein. In her calls to the FBI, she claims
that she is doing a documentary and writing a book regarding human trafficking and about Epstein's use of a
modeling agency to assist him in trafficking underage girls into the United States to use in sexual conduct.
A few years ago, FBI tried to get documentation from her "source" regarding these allegations, but the "source"
didn't appear for interviews and never provided documentation. Sarnoff recently began calling FBI Miami to
again make these allegations. It is my understanding that FBI has told Sarnoff that if her "source" wants to come
forward with evidence and be interviewed, FBI is more than willing to listen, but Sarnoff is dissatisfied with that
response.
Obviously I haven't called
back, but I assume that she is calling us for the same reason. If so, can
you direct her to
at the FBI?
Thank you!
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00019171


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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
(USANYS)"
)"
Cc:
(USANYS)"
Subject: RE: Maxwell superseder prosecution memo
Date: Wed, 24 Mar 2021 03:10:23 +0000
Attachments: Maxwell_S2_Indictment_v1.docx
Attached is a draft superseding indictment.
Thanks,
From:
Sent: Tuesday, March 23, 2021 11:29 AM
To:
(USANYS)
>;
is
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Maxwell superseder prosecution memo
Sure thing, will aim to get you a draft today, thanks.
From:
(USANYS)
Sent: Tuesday, March 23, 2021 10:32 AM
To:
)
is
)
is
(USANYS)
is
)
Cc:
(USANYS)
Subject: FW: Maxwell superseder prosecution memo
Hi team, we have asked
what the Brass wants to do in terms of review/meeting, and will let you know. In the
meantime and mindful of the Monday GJ date, do you mind putting together a draft indictment for us to review? Thanks!
From:
(USANYS)
Sent: Friday, March 19, 2021 3:34 PM
To:
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
(USANYS)
is
Subject: RE: Maxwell superseder prosecution memo
Thanks,
From:
)
Sent: Friday, March 19, 2021 3:24 PM
To:
(USANYS)
i
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
EFTA00020333

=== Page 2 ===
is
(USANYS)
is
Subject: Maxwell superseder prosecution memo
All,
Attached please find a prosecution memorandum requesting authorization to seek a superseding indictment charging
Maxwell with additional criminal offenses. For reference, I have also attached the two prior prosecution memos regarding
the original indictment in this case. We have tentatively scheduled grand jury time for Monday, March 29th.
Thanks,
EFTA00020334


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=== Page 1 ===
EXHIBIT G
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
)
IN THE MATTER OF THE ESTATE OF:
)
PROBATE NO. ST-19-PB-80
)
JEFFREY E. EPSTEIN,
)
ACTION FOR TESTATE
deceased.
)
ADMINISTRATION
)
ORDER
THIS MATTER is before the Court on the Co-Executors' Status Report on Voluntary
Compensation Program and Presentation of Program Protocol filed on June 1, 2020, wherein, in
pertinent part, the Co-Executor notify that all interested parties have finalized and are in support of
the protocol for the Epstein Victims' Compensation Program (hereinafter "the Program"). The
Court having received testimony concerning the Program at the hearing held on February 4, 2020,
and having reviewed said Status Report, it is hereby
ORDERED that the Expedited Motion for Establishment of a Voluntary Claims
Resolution Program filed on November 14, 2019, is GRANTED; and it is further
ORDERED that the Co-Executors are AUTHORIZED to commence the Epstein Victims'
Compensation Program on or about June 15, 2020.
Dated: June 2. , 2020
CAROLYN CPPH P. HERMON-PERCELL
Magistrate Judge of the Superior Court of the Virgin Islands
ATTEST:
TAMARA CHARLES
Clerk of the Court
By: & Thodge
EDOTCIA THOMAS-HODGE
Court Clerk Supervisor 6/3/2020
'At the hearing held on February 4, 2020, while the Court did not allow the Attorney General of the U.S. Virgin
Islands to intervene, the Court did request the Co-Executors and the Attorney General to resolve their differences
concerning the proposed compensation program, which has garnered the support of all interested parties, including
claimants' counsel. The Co-Executors now inform that "[b]ecause the need for the Program has grown increasingly
urgent, and with the support of claimants' counsel and the USVI Attorney General - and because the remaining
impediments have been resolved and the interested parties have consented to the Protocol," they and the Attorney
General have reached an agreement in which the latter will promptly lift previously imposed liens to pay amounts
owed for the Program and to begin funding the Program's active operations, including payment of compensation
determinations to eligible claimants. Co-Executors' Status Report on Voluntary Compensation Program and
Presentation of Program Protocol, at 6, June 1, 2020.
EFTA00019448


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Meet and Confer
Date: Mon, 22 Mar 2021 19:01:58 +0000
Attachments: Exhibit_11_(Proposed_Redactions_Per_Order).pdf;
2021.02.26_Government_Ommibus_Opposition_to_Maxwell_Defense_Motions_FINAL_(Pr
oposed_Redactions_Per_Order).pdf
Inline-Images: image001.jpg; image002.jpg
Thanks for your email. In accordance with Judge Nathan's order, we are writing to confer regarding Exhibit 11 and your
cover letter dated March 9, 2021. Attached please find proposed redactions to Exhibit 11. We do not believe any
redactions are necessary to your cover letter.
We intend to the file the brief with the redactions as set forth in Judge Nathan's March 18, 2021 order, attached here for
your convenience. We note that the redactions contained on pages 118 to 119 redact quotations from and references to
a document that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also
under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see
whether you in fact want those redactions removed. We will defer to you on whether these should be redacted.
Best,
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Monday, March 22, 2021 2:29 PM
Subject: Meet and Confer
Per Judge Nathan's order, we need to meet and confer today about proposed redactions to Exhibit 11 of your opposition
and to our letter dated March 9, 2021 regarding redactions. We are free from now through the rest of the afternoon.
Please let us know what works for you.
Regards,
Chris
Christian R Everdell
EFTA00019029

=== Page 2 ===
COHEN & GRESSER LLP
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00019030


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c0:
=== Page 1 ===
From:
To:
Subject: 2020-03-10, prosecution memo,
Date: Wed, 01 Apr 2020 05:46:56 +0000
Attachments: 2020-03-10,_prosecution_memo
EFTA00019434


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=== Page 1 ===
Event: Proffer:
Organizer:
Class: X-PERSONAL
Date Created: 2025-11-26 15:25:49 +0000
Date Modified: 2025-11-26 15:25:49 +0000
Priority: 5
Attendee:
(NY) (FBI)
EFTA00019846


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=== Page 1 ===
Subject: RE: Application for Search Warrant
Date: Tue, 27 Oct 2020 19:36:43 +0000
Attachments:
Apologies, attached please find the flattened pdfs. I also realized that the versions I submitted this morning included
Judge Nathan's name instead of Judge Wang's name. I have corrected the documents to reflect that this application is
being submitted to Judge Wang.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Sent: Tuesday, October 27, 2020 1:52 PM
Subject: RE: Application for Search Warrant
Please flatten your PDFs and resend for the Judge to review.
Thank you
Sent: Tuesday, October 27, 2020 9:18 AM
Subject: Application for Search Warrant
CAUTION - EXTERNAL:
Good morning,
Attached for Judge Wang's consideration please find an application for the issuance of a search warrant, the four exhibits
referenced in that application, and a proposed search warrant.
EFTA00018615

=== Page 2 ===
The agent is available this afternoon and tomorrow morning to swear out the warrant. I can be reached by email or on
my cellphone at
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00018616


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From:
"
(USANYS)"
To:
)"
Subject: RE: set book
Date: Wed, 29 Sep 2021 19:54:13 +0000
Importance: Normal
Attachments: Epstein_Photo_Book_6.16.21.docx
Attached. It is in the 18th production, FYI, and saved here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\27 Eighteenth Production (2021-07-28)\!Originals
From:
)
Sent: Wednesday, September 29, 2021 3:49 PM
To:
(USANYS)
Subject: set book
Do you have a copy you could email me?
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
"
T
Cc:
Subject: co-conspirator memo
Date: Wed, 14 Aug 2019 18:36:01 +0000
Attachments:
A draft of the memo is attached.
and I jointly drafted, and we had a little difficulty with more detail because
we're waiting for the FBI to send us some interview notes, but this is the level of detail we're able to provide at this point.
Thanks,
Assistant United States Attorney
0007
(212) 637-2225
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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
New York, New York 10007
March 29, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02743103 through SDNY_GM_02743292.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 02743103
SDNY_GM_02743136
SDNY_GM_02743137
SDNY_GM_02743142
Confidential
SDNY_GM_02743143
SDNY_GM_02743156
SDNY GM 02743157
SDNY GM 02743188
Confidential
EFTA00019084

=== Page 2 ===
Page 2
SDNY GM 02743189
SDNY GM 02743292
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00019085


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=== Page 1 ===
From:
Subject: Bob Fiske called re the Epstein indictment
Date: Tue, 09 Jul 2019 13:26:35 +0000
Importance: Normal
EFTA00018163


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=== Page 1 ===
From:
To:
Subject: FW: Application for Amended SW
Date: Thu, 22 Oct 2020 18:46:17 +0000
Attachments: Application_for_Amended_Warrant_for_3_Drives_from_NY_Residence.rd.docx
My edits. The paragraph I added per our discussion was #10.
From:
Sent: Thursday, October 22, 2020 1:07 PM
To:
is
Cc:
is
Subject: Application for Amended SW
Chiefs,
Thanks very much for talking this morning. As discussed, attached is a draft application for an amended search warrant
correcting the FBI barcode numbers for 3 devices that were seized from Epstein's NY residence. In case it's useful, I'm also
attaching the exhibits that are referenced in the draft application.
Thanks,
EFTA00017802


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=== Page 1 ===
From:
@usa.doj.gov>
To: David Oscar Markus <dmarkus@markuslaw.com>,
(USANYS)"
@usa.doj.gov>
Cc:
@usa.doj.gov>
Subject: RE: U.S. V. Ghislaine Maxwell
Date: Wed, 31 Mar 2021 15:15:15 +0000
David,
Confirmed, the Government opposes the motion for bail and intends to file a response.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637
From: David Oscar Markus <dmarkus@markuslaw.com>
Sent: Wednesday, March 31, 2021 11:02 AM
To:
Subject: Re: U.S. V. Ghislaine Maxwell
We are preparing our motion for bail in the Second Circuit and need to inform the Court of the government's
position. We intend to let the Court know that the Government's opposes Ms. Maxwell's motion and intends to
file a response. Please confirm.
Thanks,
David
--David Oscar Markus
EFTA00020439

=== Page 2 ===
markuslaw.com
305-379
From:
(USANYS)
@usdoj.gov>
Sent: Thursday, March 25, 2021 7:10 PM
To: David Oscar Markus
Cc:
(USANYS);
(USANYS); Christian Everdell; Bobbi Sternheim (bcsternheim@mac.com);
Mark S. Cohen
Subject: RE: U.S. V. Ghislaine Maxwell
David,
Thanks for letting us know that you'll be counsel on this appeal. As an initial matter, the majority of the docket
entries you've referenced do not appear to be redacted. In any event, you may obtain these materials from
defense counsel -- I've copied them here. This case is already governed by a protective order (ECF No. 36),
which is binding on all counsel.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-
From: David Oscar Markus <dmarkus@markuslaw.com>
Sent: Thursday, March 25, 2021 5:33 PM
To:
EFTA00020440

=== Page 3 ===
@usa.doj.gov>
Subject: U.S. V. Ghislaine Maxwell
Good afternoon counsel:
I have been engaged to represent Ghislaine Maxwell in her appeal from the denial of her third application for
bail. In preparing this appeal, I will need access to certain unredacted documents, including docket entries 4, 18,
22, 97, 100, 103, 106, 159, 160, 165, 171, 169. Do you have any objection to me having access to these
unredacted documents? (There may be additional documents that I need, but I have not identified them as of
yet.) I'm happy to enter into a protective order with the government if you believe that is necessary. I plan on
filing the appeal next week, so I would appreciate it if you could get back to me as soon as possible.
Thank you,
David
--David Oscar Markus
markuslaw.com
305-379
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From: "Hutner, Florence (OCME)"
To:
Subject: RE: Epstein FOIA Release
Date: Fri, 02 Jul 2021 20:44:08 +0000
Thanks so much; same to you.
Florence Hutner
General Counsel
Office of Chief Medical Examiner
Tel:
Mobile:
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is prohibited.
If you have received this communication in error, please notify us immediately by telephone or reply e-mail and permanently delete it and
any copies from your system files.
From:
Sent: Friday, July 2, 2021 3:18 PM
To: Hutner, Florence (OCME)
Subject: RE: Epstein FOIA Release
Florence,
The redacted autopsy reported, as produced to the Times, is attached. I provided notice to Mark Epstein's attorney this
morning.
Have a good holiday weekend.
From: Hutner, Florence (OCME)
Sent: Thursday, July 1, 2021 11:39 AM
To:
Subject: RE: Epstein FOIA Release
Thanks very much on both counts.
Florence Hutner
General Counsel
Office of Chief Medical Examiner
Tel:
Mobile:
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is prohibited.
EFTA00018502

=== Page 2 ===
If you have received this communication in error, please notify us immediately by telephone or reply e-mail and permanently delete it and
any copies from your system files.
From:
Sent: Thursday, July 1, 2021 11:38 AM
To: Hutner, Florence (OCME)
Subject: Epstein FOIA Release
Hi Florence,
Following up on our call yesterday, we will send you a copy of the redacted autopsy report tomorrow, after it's produced.
We also intend to call Mark Epstein's lawyer tomorrow morning to give her a courtesy head's up about the release.
Thanks,
U.S. Attorney's Office
Southern District of New York
Desk
Cell
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein update
Date: Sat, 10 Aug 2019 20:21:55 +0000
Yeah. I'll get on top of that shortly.
From:
Sent: Saturday, August 10, 2019 4:21 PM
To:
Cc:
(
Subject: RE: Epstein update
Sorry but just related on the FBI and DOJ-OIG investigation, can we get a contact at each of those?? I know there's
apparently no AUSA assigned yet to the FBI side, but for example I would want to let FBI and OIG know that someone is
claiming to be at MCC and calling Epstein's associates to have them pick up the body - they'll be more likely to have
traction with BOP than we will.
From:
Sent: Saturday, August 10, 2019 16:20
To:
Cc:
(
Subject: RE: Epstein update
Yeah of course. In some ways I actually hope this is a hoax because if not, it's completely insane. And I just called
but he didn't pick up.
Separately, and speaking of the FBI investigation, defense counsel also says that they're starting to get people calling them
who claim to have information relevant to Epstein's death, and are wondering if there is an investigative point person to
whom they can direct any such people?
From:
Sent: Saturday, August 10, 2019 16:17
To:
Cc:
(
Subject: RE: Epstein update
Removing BOP. They should NOT be releasing the body without confirming with FBI and DOJ-IG. Please discuss that with
them.
From:
Sent: Saturday, August 10, 2019 4:14 PM
To:
EFTA00018970

=== Page 2 ===
Cc:
Subject: RE: Epstein update
l'll call you separately in a moment, but just in case email is faster, I just received a phone call from defense counsel that a
person close to Mr. Epstein received a phone call from an individual named
(phonetic) who claimed to be
an investigator with the MCC and told the individual that Mr. Epstein's body was ready to be picked up at the hospital and
that the individual could make arrangements for retrieval of the body.
left his phone number as
Can you please confirm whether that individual is in fact with BOP and/or MCC? Defense counsel is understandably
concerned that they (and others with connections with Mr. Epstein) are starting to get hoax or otherwise inaccurate
information through phone calls and emails. And we would again respectfully but urgently request that if there is
information like this that needs to go to representatives for Mr. Epstein, that it come to us so we can pass it along to his
counsel with confidence that it is true and accurate.
(Separately, if it is accurate that BOP / MCC is prepared to release Mr. Epstein's body, his defense counsel is extremely
concerned about whether that has been enough time for a full autopsy and any other investigative steps, and we would
want to confirm that the FBI team addressing this matter has also been informed-but that's only if this is not a hoax,
obviously.)
Please advise as soon as possible, as the individual is waiting to know whether they should take steps to retrieve the body.
thank you,
From:
Sent: Saturday, August 10, 2019 15:56
To:
is
Cc:
Subject: RE: Epstein update
Hi
I'm checking in to see if you're able to provide us with additional information. I'm
when you have a moment.
Thanks,
From:
Sent: Saturday, August 10, 2019 11:42 AM
To:
Cc:
Subject: Re: Epstein update
Hi
MCC Administrators have been in touch with
at the USMS since early this morning. I too have been in touch
with
since a little after 9 am, at which time I shared the limited information I had. The press release is the sum total of
the information we have at this time pending the investigation. I am going into the secure perimeter to see if there is
EFTA00018971

=== Page 3 ===
more information to share, but please be advised that some of what I get may be shared with your office but not further
since it is an open investigation.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
>>>
)"
> 8/10/2019 11:30 AM >>>
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic information so that we
can relay it to his attorneys who can relay it to his family. When can we expect to get either some sort of statement we can
pass along to counsel as accurate and reliable or have a call with someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP, and given the
BOP press release that was just put out I assume we need to speak with someone there. Please advise.
Thank you.
On Aug 10, 2019, at 10:43,
> wrote:
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be seeing
information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know as soon as possible
the very basic facts, such as time and cause of death at the absolute minimum. It has now been hours since this was
reported publicly. Please advise when we can expect to receive either a written report on those basic facts or when we can
have a call to get that information to relay to his counsel. It is extraordinarily frustrating to have to tell them that we have
less information than the press. Please advise.
Thank you,
On Aug 10, 2019, at 08:46,
> wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
Cc:
is
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
EFTA00018972

=== Page 4 ===
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
> wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: FW: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Letter re Sealing of Renewed Bail
Motion (to be Filed Under Seal)
Date: Wed, 25 Nov 2020 20:47:03 +0000
Attachments: 2020.11.25_Letter_to_Judge_Nathan_re_Sealing_of_Renewed_Bail_Motion.PDF
Inline-Images: image005.jpg; image006.jpg
FYI
From: Christian Everdell
Sent: Wednesday, November 25, 2020 2:12 PM
To:
Cc:
(USANYS)
>;
(USANYS)
is
(USANYS)
>; Mark S. Cohen
>; BOBBI C STERNHEIM
<bcsternheim@mac.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>; Laura Menninger <lmenninger@hmflaw.com>
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Letter re Sealing of Renewed Bail Motion (to be Filed Under Seal)
Dear Judge Nathan -
Please see the attached letter to be filed under seal and submitted to the Court and all counsel pursuant to Section 2(B) of
Your Honor's Individual Practices in Criminal Cases.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein forfeiture
Date: Wed, 14 Aug 2019 13:12:43 +0000
Probably - although her posture is different now that she is the principal subject; she may think the chances of being
charged have gone up and want to talk us out of it.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 9:06 AM
To:
(USANYS)
Subject: Re: Epstein forfeiture
I can't conceive of her being willing to come in with no protection at all if she wasn't willing to come in under a proffer
agreement.
Sent from my iPhone
On Aug 14, 2019, at 9:03 AM,
(USANYS)
wrote:
He also wants us to reach out to
counsel, make clear that the investigation is active and continuing, and either
ask if there is any movement on her position/potential for cooperation against others, and/or if she wants to speak to us
under an innocence proffer and explain her side of the story, including victimization.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 9:01 AM
To:
(USANYS)
is
(USANYS) 3
Subject: Epstein forfeiture
I
ran into Geoff this morning, and he said he'd like to meet this afternoon - I think around 230 or 3, does that work? FYI,
he sounds more bullish than I think we were thinking, so there may need to be some expectations managing.
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
)"
(USANYS)"
Subject: RE: Maxwell - RTC
Date: Tue, 12 Oct 2021 00:14:20 +0000
Attachments: Maxwell_RTC_v11.docx
Hi
We just wanted to check in and see if you think you'll have a chance to look at the Maxwell RTC before we send it to the
defense. We're planning to do that on October 20, and if you have time to look at this before then, we'd really like to
incorporate your comments.
Thanks!
From:
)
Sent: Thursday, September 30, 2021 10:50 AM
To
Subject: Maxwell - RTC
Hi
I hope all's well! Attached is a draft of our RTC in the Maxwell case. If you have time to look at it, we'd love any
comments you might have.
In terms of timing, we have to file a joint proposed RTC on October 27, so we are thinking of sending this to the defense a
week or so before that.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
From:
To:
Subject: Text messages 2
Date: Sat, 21 Dec 2019 14:30:26 +0000
Inline-Images: IMG_2419.jpg; IMG_2420.jpg; IMG_2421.jpg; IMG_2422.jpg
EFTA00018273

=== Page 2 ===
8:49
...
No SMS connection
Monday, Jul 15 . 8:04 AM
Hi
the number
-
for today's call at 1pm
is
and the
code
Thanks
Monday, Jul 15 . 9:10 AM
Thanks!
Monday, Jul 15 . 1:06 PM
Hi
-
are you still
available for today's
meeting?
Tuesdav Aug 13 6.15 PM
+
Text message
SMS

=== Page 3 ===
EFTA00018275

=== Page 4 ===
8:49
No SMS connection
Tuesday, Aug 13 6:15 PM
Well I guess I have a few
more questions these
days! I've had a journalist
knock on my door three
times today.. I'm rather
upset and curious to
know is my name open
for the public to know in
this case? I'd like to chat
some whenever you can.
I'm taking tomorrow off
but I'll be available at any
hour now that
is
fully involved. Sorry I didn't
make the last interview
life has been so overly
hectic and busy with
but I really got
some questions about
going forward with some
of this
Text message
SMS

=== Page 5 ===
EFTA00018277

=== Page 6 ===
8:49
No SMS connection
Thursday, Aug 15 . 11:28 AM
It's ok. What day and time
will be good for you. And
yes
can answer some
of your questions. Pls let
me know SO that I can
coordinate it with
Thanks
Today around 2-4..
tomorrow anytime!
Ok let me call
to see
if the conference room
is available because
conference phone is in
that room.
+
Text message
SMS

=== Page 7 ===
EFTA00018279

=== Page 8 ===
8:49
X
1
No SMS connection
No worries, thank you!
W Γ set, as soon as I
receive the number to call
in I'll send it to you
You're awesome!!
Ur the awesome, ur doing
something to be in control
of your life
The phone number is
participant
code
Looking
forward to talking to you.
Set for 2pm today.
+
Text message
SMS

=== Page 9 ===
Sent from my iPhone
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=== Page 1 ===
From:
To:
Subject:
new and redlined
Date: Fri, 27 Mar 2020 21:34:03 +0000
Attachments: 2020.03.27
draft_submission.pdf;
[Compare_New]_2020.03.27
draft_submission.pdf
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Potential Victim
Date: Tue, 09 Jul 2019 13:33:55 +0000
Importance: Normal
I'm on the subway but start without me and I'll get the rundown
Sent from my iPhone
> On Jul 9, 2019, at 09:31,
wrote:
V
V
Great
>
> Sent from my iPhone
V
On Jul 9, 2019, at 9:29 AM,
wrote:
Sure- we have a call with counsel for
at 10, can we meet at 945?
>>
Sent from my iPhone
On Jul 9, 2019, at 9:14 AM,
wrote:
I just got a call from
on this and other issues. Can we circle up in about 15 or 20 minutes?
Sent from my iPhone
On Jul 8, 2019, at 8:54 PM,
wrote:
Thanks,
We'll follow up.
Sent from my iPhone
On Jul 8, 2019, at 8:38 PM,
wrote:
The CSOs received a telephone call from a female who identified herself as
who allegedly has information about Epstein.
gave a return number of
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 1 of 5
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 21, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in opposition to the defendant's letter of
August 17, 2020 (the "Defense Letter"), requesting that the Court enter an order permitting the
defendant to file under seal in certain civil cases (the "Civil Cases") discovery materials produced
by the Government in the instant criminal case, and to refer to, but not file, additional other
discovery materials produced by the Government in the Civil Cases. Those applications should
be denied.
As an initial matter, the Government has already produced, and will continue to produce,
substantial volumes of materials in discovery consistent with its obligations. Those include
materials the Government obtained via search warrant, grand jury subpoenas, or other investigative
methods available only to the Government. Indeed, the Government has already produced more
than 165,000 pages of discovery to the defense, including the materials relevant to the Defense
Letter. Through her most recent application, the defendant seeks permission to use, in unrelated
civil litigation, materials produced pursuant to the protective order in this case and designated
"Confidential" thereunder. As detailed herein, the Government's designation is entirely
appropriate given that the materials-court orders and applications-have been kept under seal by
the issuing judges, and pertain to an ongoing criminal investigation.
1 The Government has drafted this letter in a manner that avoids revealing the contents of sealed
materials and grand jury information. Accordingly, the Government does not seek permission to
seal or redact this submission. Because the Defense Letter repeatedly references, and attaches as
exhibits, materials that are sealed and that would jeopardize an ongoing grand jury investigation if
filed publicly, the Government intends to submit a separate letter, under seal, proposing redactions
to the Defense Letter and requesting that the attachments to the Defense Letter be filed under seal.
EFTA00017805

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Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 2 of 5
Honorable Alison J. Nathan
August 21, 2020
Page 2
In particular, the Defense Letter seeks this Court's authorization to use materials relating
to applications the Government made seeking the modification of certain protective orders in other
judicial proceedings. By way of background, the Government sought such modifications to permit
compliance with criminal grand jury subpoenas (the "Subpoenas"). Those Subpoenas were issued
to a certain recipient (the "Recipient") after the Government opened a grand jury investigation into
Jeffrey Epstein and his possible co-conspirators. For obvious reasons and in keeping with its
standard practice, the Government did not notify the defendant or her counsel that it had issued
the Subpoenas. In response to receiving the Subpoenas, the Recipient advised the Government
that it believed that certain existing protective orders precluded full compliance. Accordingly, in
or about February 2019, the Government applied ex parte and under seal to each relevant court to
request modification of the respective protective orders to permit compliance with the Subpoenas.
In or about April 2019, one court ("Court-1") granted the Government's application, and permitted
that the Government share its order-and only that order, which itself prohibited further
dissemination-to the Recipient. 2 Subsequently, the second court ("Court-2") denied the
Government's application. Because the relevant grand jury investigation remains ongoing, both
Court-1 and Court-2 have ordered that the filings regarding the Subpoenas remain under seal,
except that both have expressly permitted the Government to produce those filings to the defendant
as part of its discovery obligations in this criminal case. The Defense Letter now seeks to use
those discovery materials in the Civil Cases.
At base, the defendant's application fundamentally misapprehends the nature and process
of criminal proceedings, and it further reflects an inappropriate effort to blur the lines between the
criminal discovery process and civil litigation. To be clear: the purpose of criminal discovery is
to enable the defendant to defend herself in the criminal action, not to provide her with a trove of
materials she can mine to her advantage in civil discovery. Her motion is nothing more than an
effort to evade the directives of the protective order entered by this Court just three weeks ago. It
should be denied for multiple reasons.
First, and as the defendant concedes, the protective order in this case expressly provides
that any and all discovery material produced to the defendant by the Government, regardless of
designation, "[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the
defense of this criminal action, and not for any civil proceeding or any purpose other than the
defense of this action." Protective Order 1(a), 10(a), 14(a) (emphasis added) (Dkt. 36). Indeed,
the defendant included that same provision, word-for-word, in her own proposed protective order.
This was not a provision about which the defendant and the Government disagreed. See
Defendant's Proposed Protective Order 1(a) (Dkt. 29-1). Yet less than a month later, the
defendant is asking the Court to sanction her effort to utilize materials produced by the
2 In the Defense Letter, the defendant argues that the Government "must have given a copy of the
sealed order" to the Recipient, which defense counsel suggests is inconsistent with the
Government's statement that it rarely provides discovery material to third parties. The defendant's
suggestion is patently incorrect. The relevant order was signed in April 2019 and was issued for
the purpose of being provided to the Recipient. Indeed the order contained an explicit provision
that it could be transmitted to the Recipient. Accordingly, the order was conveyed to the Recipient
well over a year before it became "discovery" in this criminal case.
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Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 3 of 5
Honorable Alison J. Nathan
August 21, 2020
Page 3
Government in discovery in this criminal case, and to which the protective order unquestionably
applies, to litigate her Civil Cases. There is no basis to modify the Protective Order here.
Second, there is good reason why both parties proposed, and the Court ordered, a protective
order that prevents the defendant from using materials obtained through the process of criminal
discovery in any of the many civil cases in which she is, or could become, a party. To allow the
defendant to do so would permit the dissemination of a vast swath of materials, including those
that are confidential due to witness privacy interests, personal identifying information of third
parties, and relevance in ongoing grand jury investigations. Here, the Government was particularly
concerned about the defendant's interests in blurring these lines because, among other reasons, her
counsel in the criminal case are also her counsel in the Civil Cases. It would be grossly
inappropriate for defense counsel to be permitted to sift through the criminal case discovery and
cherry-pick materials they may believe could provide some advantage in their efforts to defend
against accusations of abuse by victim plaintiffs, delay court-ordered disclosure of previously-
sealed materials, or any other legal effort the defendant may be undertaking at any particular time.
And yet that is what the defendant proposes.
Third, the specific documents at issue pertain to ex parte applications made as part of an
ongoing grand jury investigation. Those documents were filed under seal and presently remain
under seal because the relevant judicial officers have ordered that all filings regarding those
matters, including the discovery materials referenced in the Defense Letter, remain sealed.3 As
the U.S. Attorney's Office for the Southern District of New York has stated publicly, the
investigation into the conduct of the defendant in this case and other possible co-conspirators of
Jeffrey Epstein remains active. The full scope and details of that investigation, however, have not
been made public.⁴ Accordingly, the materials the defendant seeks to file in the Civil Cases were
produced under a "Confidential" designation. Any argument that such materials are not
"confidential" would not only run contrary to the sealing orders entered by other courts, but also
misapprehends the importance of maintaining the confidentiality of criminal investigations.5 See,
3 The only exceptions to those sealing orders are (1) as noted above, the permission from Court-1
to provide the April 2019 order alone to the Recipient, and, (2) pursuant to separate permissions
the Government has obtained in connection with its discovery obligations, that the entirety of the
record relating to the Subpoenas may be provided to the defendant as discovery in this case. The
defendant's claim that the relevant materials were produced to the defendant in discovery without
any application to the sealing courts, Def. Ltr. at 7, is incorrect.
4 To the extent it would be useful to this Court for the Government to further elaborate on the
nature of the ongoing grand jury investigation, the Government is prepared to file a supplemental
letter specifically on that subject ex parte and under seal should the Court request such an
explanation.
5 Moreover, if counsel for the defendant in her Civil Cases believe that certain documents are
improperly sealed, there is no impediment to counsel making sealed applications to Court-1 and
Court-2, respectively, to unseal the relevant materials. Presumably they have not done so because
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Honorable Alison J. Nathan
August 21, 2020
Page 4
e.g., United States V. Smith, 985 F. Supp. 2d 506, 531 (S.D.N.Y. 2013) ("As a general proposition,
courts have repeatedly recognized that materials, including even judicial documents which are
presumptively accessible, can be kept from the public if their dissemination might "adversely affect
law enforcement interests.") (citing United States V. Amodeo, 71 F.3d 1044, 1050)); see also
United States V. Park, 619 F. Supp. 2d 89, 94 (S.D.N.Y. 2009) (holding that the need to "maintain
the secrecy of the Government's investigation" outweighed the public's right of access to certain
sentencing documents).
Fourth, defense counsel cites not a single case to support the argument that a criminal
defendant should be permitted to use criminal discovery materials in her civil cases. Nor is the
Government aware of any. Though precedent on this issue appears to be somewhat sparse-
perhaps because few defendants attempt such a maneuver-see United States V. Calderon, 15 Cr.
025, 2017 WL 6453344, at *3 (D. Conn. Dec. 1, 2017) (discussing the relative lack of specific
guidance in the context of an application to modify protective orders in criminal cases), see also
United States V. Morales, 807 F.3d 717, 721 (5th Cir. 2015) ("[m]otions to modify protective
orders in criminal cases appear to be infrequent"), decisions that do exist have rejected the kind of
blurring of the line between criminal and civil proceedings that the defendant attempts here. See
Calderon, 2017 WL 6453344, at 5-6 (denying a defendant's application for modification of a
criminal protective order so he could use certain discovery materials in a FOIA suit); United States
V. DeNunzio, --- F. Supp. 3d ---, 2020 WL 1495880, at *2-3 (D. Mass. March 27, 2020) (denying
a defendant's motion to modify two protective orders in his criminal case for the purpose of
pursuing claims in a civil action, even following the completion of trial).
Absent any authority upon which to rely, the defendant, in urging a contrary conclusion,
makes various assertions and accusations, none of which warrant a different outcome. In
particular, there is no merit or particular relevance to the defendant's argument that the
Government secretly obtained a volume of materials relevant to its criminal case without telling
the defendant. That is how grand jury subpoenas and investigations frequently work. Defense
counsel's overheated rhetoric notwithstanding, there is simply nothing nefarious about the
Government obtaining materials through grand jury subpoena process, let alone anything about
the manner in which the Government obtained these materials that warrants the relief requested.
Certainly to the extent the defendant asserts that her adversary in civil litigation has
engaged in some sort of improper conduct-assertions the Government by no means intends to
suggest agreement with-such arguments even if credited would not be a proper basis to
circumvent the plain language of the protective order (or the existing sealing orders) in this case.
In any event, of the materials at issue, the only document the defendant's civil adversary has access
to is the lone April 2019 order, meaning any purported imbalance between the parties in the Civil
Cases at this stage is significantly overstated. And to the extent the defendant may seek to make
similar accusations against the Government or challenge the manner in which the Government
obtained the materials at issue-a challenge that itself would not justify the relief presently
they recognize that the materials are appropriately sealed as relating to an ongoing grand jury
investigation.
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Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 5 of 5
Honorable Alison J. Nathan
August 21, 2020
Page 5
requested-the defendant can make such arguments, and the Government can and will vigorously
oppose them, at the appropriate stage in this case.
Finally, to the extent the defendant contends that the relief requested is somehow necessary
to her ability to bring issues to the attention of other courts, the Defense Letter completely fails to
explain what legal argument she wishes to make in her Civil Cases based on the discovery
materials she has identified or what relevance those materials have to the litigation of the Civil
Cases. The fact that the Government issued grand jury subpoenas and obtained court authorization
for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the
Civil Cases. To the extent the defendant argues that the requested relief is necessary to ensure that
courts adjudicating the Civil Cases are aware of the existence of the documents at issue, the
defendant identifies no specific reason why these materials are relevant to the issues pending in
those cases, other than to falsely accuse the Recipient and the Government of some sort of
malfeasance.
In sum, the defendant's arguments in favor of her application offer no explanation of the
relevant legal theory the materials would support, not to mention a compelling reason for this Court
to permit an end-run around the protective order and permit the use of criminal discovery to litigate
a civil case. Accordingly, the application in the Defense Letter should be denied.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
/s
/
/
Assistant United States Attorneys
Southern District of New York
Tel:
Cc:
All counsel of record, via ECF
6 If anything, the Defense Letter suggests that the defendant intends to use criminal discovery
materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those
cases and made in a forum in which the Government is not a party and would have no opportunity
to respond.
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=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
Subject: Accepted: Epstein FOIA Moot
Date: Fri, 26 Mar 2021 19:21:01 +0000
Importance: Normal
Attachments: unnamed
EFTA00020399


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=== Page 1 ===
From:
<
To:
<
>
Cc:
Subject: RE: Epstein
Date: Tue, 13 Aug 2019 17:52:13 +0000
Thanks
>>>
(USANYS)" <
> 8/13/2019 1:18 PM >>>
This is the only contact we have:
Palm Beach County Sheriff's Office
Violent Crimes Division / Homicide
We don't have any other documents or information.
From:
Sent: Tuesday, August 13, 2019 12:19 PM
To:
(USANYS)
Cc:
Subject: Epstein
Good afternoon
I hope all is well. I understand the prosecution team has been walled off from the investigation. Do you have access to his
records from his prior incarceration? If not, do you have a contact for his prior facility or the USAO in Florida? I have been
asked to track down certain documentation in reference thereto in relation to the various investigations into the incident this
past weekend.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
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Page 1 of 1
- Suicide Watch/Psych Observation Update
From:
To:
Suicide Watch/Psych Observation Update
Date:
7/9/2019 8:11 AM
Subject:
Suicide Watch/Psych Observation Update
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Thank you,
8/10/2019
EFTA00018977

=== Page 2 ===
Page 1 of 1
- Wednesday AM Suicide Watch/Psych Observation Update
From:
To:
Date:
7/10/2019 10:16 AM
Subject: Wednesday AM Suicide Watch/Psych Observation Update
Wednesday AM Suicide Watch/Psych Observation Update
Inmate Epstein #76318-054 was removed from Psychological Observation and placed in the SHU.
Suicide Watch
None
Psych Observation
1. Gebremariam #79792-007 (Forensic)
Very respectfully,
.
Forensic Psychologist
LT, U.S. Public Health Service
U.S. Department of Justice
Federal Bureau of Prisons
Metropolitan Correctional Center
Office:
Fax:
E-mail:
"This message is intended for official use and may contain SENSITIVE information. If this message contains
SENSITIVE information, it should be properly delivered, labeled, stored, and disposed of according to policy."
le://CUSers/bop1468/AppData/Local/Temp/XPgrpwise/5D25BB04NYMDOM1NY.
8/10/2019
EFTA00018978

=== Page 3 ===
Page 1 of 1
- Suicide Watch/Psych Observation Update
From:
To:
Suicide Watch/Psych Observation Update
Date:
7/23/2019 8:32 AM
Subject: Suicide Watch/Psych Observation Update
Suicide Watch
1. Epstein #76318-054
Psych Observation
None
Thank you,
file://C/Users/bop14688/AppData/Local/Temp/XPgrpwise/5D36C60BNYMDOMINYM. 8/10/2019
EFTA00018979

=== Page 4 ===
Page 1 of 1
- Wednesday AM Suicide Watch/Psych Observation Update
From:
To:
Date:
7/24/2019 9:21 AM
Subject: Wednesday AM Suicide Watch/Psych Observation Update
Wednesday AM Suicide Watch/Psych Observation Update
Inmate Epstein #76318-054 is being removed from Suicide Watch and stepped down to Psychological
Observation.
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Very respectfully,
Forensic Psychologist
LT, U.S. Public Health Service
U.S. Department of Justice
Federal Bureau of Prisons
Metropolitan Correctional Center
Office:
Fax:
E-mail:
"This message is intended for official use and may contain SENSITIVE information. If this message contains
SENSITIVE information, it should be properly delivered, labeled, stored, and disposed of according to policy."
8/10/2019
EFTA00018980


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
UNITED STATES OF AMERICA
:
-V.-
:
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
Defendant.
:
X
THE GOVERNMENT'S MEMORANDUM
IN SUPPORT OF DETENTION
AUDREY STRAUSS
Acting United States Attorney
Southern District of New York
Attorney for the United States of America
Assistant United States Attorneys
- Of Counsel -
EFTA00018505

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Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 2 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
UNITED STATES OF AMERICA
:
-V.-
:
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
Defendant.
:
X
THE GOVERNMENT'S MEMORANDUM
IN SUPPORT OF DETENTION
For the reasons set forth herein, the Government respectfully submits that Ghislaine
Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the
statutory presumption that no condition or combination of conditions will reasonably assure the
appearance of the defendant as required, 18 U.S.C. § 3142(e)(3)(E); and that the Court should
therefore order her detained.
The charges in this case are unquestionably serious: the Indictment alleges that Ghislaine
Maxwell, in partnership with Jeffrey Epstein, a serial sexual predator, exploited and abused young
girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real
prospect of serving many years in prison. The strength of the Government's evidence and the
substantial prison term the defendant would face upon conviction all create a strong incentive for
the defendant to flee. That risk is only amplified by the defendant's extensive international ties,
her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United
States. In short, Maxwell has three passports, large sums of money, extensive international
connections, and absolutely no reason to stay in the United States and face the possibility of a
lengthy prison sentence.
1
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=== Page 3 ===
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 3 of 10
BACKGROUND
On June 29, 2020, a federal grand jury in the Southern District of New York returned a
sealed indictment (the "Indictment") charging the defendant with one count of conspiracy to entice
minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. $ 371; one count of enticing
a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. $ 2422 and 2; one count of
conspiracy to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. $ 371;
one count of transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. $ 2423
and 2; and two counts of perjury, in violation of 18 U.S.C. $ 1623.
The charges arise from a scheme to sexually abuse underage girls at Epstein's properties
in New York, Florida, and New Mexico, between approximately 1994 and 1997. During that time,
Maxwell had a personal and professional relationship with Epstein and was one of his closest
associates.
Beginning in at least 1994, the defendant enticed and groomed multiple minor girls to
engage in sex acts with Epstein, through a variety of means and methods. In particular, she played
a key role in Epstein's abuse of minors by helping Epstein to identify, groom, and ultimately abuse
underage girls. As a part of their scheme, the defendant and Epstein enticed and caused minor
victims to travel to Epstein's residences in different states, which the defendant knew and intended
would result in their grooming for and subjection to sexual abuse.
As the Indictment details, the defendant enticed and groomed minor girls to be abused in
multiple ways. For example, she attempted to befriend certain victims by asking them about their
lives, taking them to the movies or on shopping trips, and encouraging their interactions with
Epstein. She put victims at ease by providing the assurance and comfort of an adult woman who
seemingly approved of Epstein's behavior. Additionally, to make victims feel indebted to Epstein,
2
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Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 4 of 10
the defendant would encourage victims to accept Epstein's offers of financial assistance, including
offers to pay for travel or educational expenses. The victims were as young as 14 years old when
they were groomed and abused by Maxwell and Epstein, both of whom knew that their victims
were minors.
The Indictment further alleges that the defendant lied under oath to conceal her crimes. In
2016, the defendant gave deposition testimony in connection with a civil lawsuit in the Southern
District of New York. During the deposition, the defendant was asked questions about her role in
facilitating the abuse of minors. The defendant repeatedly lied under oath when questioned about
her conduct with minor girls.
ARGUMENT
I.
Applicable Law
Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to
order a defendant's detention pending trial upon a determination that the defendant is either a
danger to the community or a risk of flight. 18 U.S.C. $ 3142(e). A finding of risk of flight must
be supported by a preponderance of the evidence. See, e.g., United States V. Patriarca, 948 F.2d
789, 793 (1st Cir. 1991); United States V. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States V.
Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by
clear and convincing evidence. See, e.g., United States V. Ferranti, 66 F.3d 540, 542 (2d Cir.
1995); Patriarca, 948 F.2d at 792; Chimurenga, 760 F.2d at 405.
The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the
nature and circumstances of the crimes charged; (2) the weight of the evidence against the person;
(3) the history and characteristics of the defendant, including the person's "character [and]
financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See
3
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Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 5 of 10
18 U.S.C. $ 3142(g). Evidentiary rules do not apply at detention hearings, and the Government is
entitled to present evidence by way of proffer, among other means. See 18 U.S.C. $ 3142(f)(2);
see also United States V. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (Government entitled
to proceed by proffer in detention hearings).
Where a judicial officer concludes after a hearing that "no condition or combination of
conditions will reasonably assure the appearance of the person as required and the safety of any
other person and the community, such judicial officer shall order the detention of the person before
trial." 18 U.S.C. $ 3142(e)(1). Additionally, where, as here, a defendant is charged with
committing an offense involving a minor victim under 18 U.S.C. §§ 2422 or 2423, it shall be
presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure
the appearance of the defendant as required and the safety of the community. 18 U.S.C.
§ 3142(e)(3)(E).
II.
Discussion
For the reasons set forth below, the defendant presents an extreme risk of flight, and
therefore she cannot overcome the statutory presumption in favor of detention in this case. Every
one of the relevant factors to be considered as to flight risk - the nature and circumstances of the
offense, the strength of the evidence, and the history and characteristics of the defendant - counsel
strongly in favor of detention.
A.
The Nature and Circumstances of the Offense and the Strength of the Evidence
The "nature and circumstances" of this offense favor detention. As the Indictment alleges,
the defendant committed serious crimes involving the sexual exploitation of minors. See 18 U.S.C.
$ 3142(g)(1) (specifically enumerating "whether the offense. involves a minor victim" as a
factor in bail applications). Indeed, the crimes of enticing and transporting minors for illegal sex
4
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Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 6 of 10
acts are so serious that both crimes carry a statutory presumption that no condition or combination
of conditions will reasonably assure the appearance of the defendant as required. 18 U.S.C. $ 3142
(e)(3)(E). The defendant repeatedly engaged in this conduct, targeting girls as young as 14 years
old, for a period of years, and involving multiple minors.
These offenses carry significant penalties, and the defendant faces up to 35 years'
imprisonment if convicted. The possibility of a substantial sentence is a significant factor in
assessing the risk of flight. See United States V. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679,
at *2 (D.N.H. Jan. 26, 2010) ("[T]he steeper the potential sentence, the more probable the flight
risk is, especially considering the strong case of the government ") (quoting United States V.
Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory
maximum of decades in prison. This fact alone would provide a compelling incentive for anyone
to flee from prosecution, but the incentive to flee is especially strong for this defendant, who, at
age 58, faces the very real prospect of spending a substantial portion of the rest of her life in prison.
The strength of the evidence in this case underscores the risk that the defendant will become
a fugitive. As the facts set forth in the Indictment make plain, the evidence in this case is strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims' account of events. This will be compelling evidence of guilt at any trial
in this case, which weighs heavily in favor of detention.
The passage of time between the defendant's conduct and these charges does not counsel
otherwise. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. $ 3283,
which was amended in 2003 to extend the limitations period for conduct that was timely as of the
5
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=== Page 7 ===
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 7 of 10
date of the amendment,¹ to permit a prosecution at any point during the lifetime of the minor
victim. See United States V. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because
Congress extended the statute of limitations for sex offenses involving minors during the time the
previous statute was still running, the extension was permissible); United States V. Pierre-Louis,
No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while
the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term
of incarceration - and thus the motive to flee - is of course only very recent.
Each of these factors - the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration — creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
B.
The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. As an
initial matter, the defendant's extensive international ties would make it exceptionally easy for her
to flee and live abroad. The defendant was born in France and raised in the United Kingdom,
where she attended school. Although she became a naturalized citizen of the United States in
2002, she also remains a citizen of the United Kingdom and France. Travel records from
United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent
international travel, including at least fifteen international flights in the last three years to locations
including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent
with her citizenship status, the defendant appears to possess passports from the United States,
France, and the United Kingdom.
1 Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until
the victim reached the age of 25, and as such, all of the relevant charges in the Indictment
remained timely as of the 2003 amendment described above.
6
EFTA00018511

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 8 of 10
In addition, the defendant appears to have access to significant financial resources that
would enable her flight from prosecution. Based on the Government's investigation to date, the
Government has identified more than 15 different bank accounts held by or associated with the
defendant from 2016 to the present, and during that same period, the total balances of those
accounts have ranged from a total of hundreds of thousands of dollars to more than $20
million. During the same period, the defendant engaged in transfers between her accounts of
hundreds of thousands of dollars at a time, including at least several such significant transfers as
recently as 2019. For example, the defendant transferred $500,000 from one of her accounts to
another in March 2019, and transferred more than $300,000 from one of her accounts to another
in July 2019. She has also reported, including as recently as 2019, that she holds one or more
foreign bank accounts containing more than a million dollars.
The defendant also appears to have reaped substantial income from a 2016 property sale.
In particular, in 2016, the defendant appears to have sold a New York City residence for $15
million through a limited liability company. On or about the date of the sale, amounts totaling
more than $14 million were then deposited into an account for which the defendant was listed as
the owner. Several days later, more than $14 million was transferred from that account into
another account opened in the name of the defendant.² In short, the defendant's financial resources
appear to be substantial, and her numerous accounts and substantial money movements render her
total financial picture opaque and indeterminate, even upon a review of bank records available to
the Government.
2 The Government additionally notes that, somewhat further back in time, in transactions occurring
between 2007 and 2011, approximately more than $20 million was transferred from accounts
associated with Jeffrey Epstein to accounts associated with the defendant, including amounts in
the millions of dollars that were then subsequently transferred back to accounts associated with
Epstein.
7
EFTA00018512

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 9 of 10
The defendant's international connections and significant financial means would present a
clear risk of flight under normal circumstances, but in this case, the risk of flight is exacerbated by
the transient nature of defendant's current lifestyle. In particular, the defendant has effectively
been in hiding for approximately a year, since an indictment against Epstein was unsealed in July
2019. Thereafter, the defendant - who had previously made many public appearances - stopped
appearing in public entirely, instead hiding out in locations in New England. Moreover, it appears
that she made intentional efforts to avoid detection, including moving locations at least twice,
switching her primary phone number (which she registered under the name "G Max") and email
address, and ordering packages for delivery with a different person listed on the shipping label.
Most recently, the defendant appears to have been hiding on a 156-acre property acquired in an
all-cash purchase in December 2019 (through a carefully anonymized LLC) in Bradford, New
Hampshire, an area to which she has no other known connections.
The defendant appears to have no ties that would motivate her to remain in the United
States. She has no children, does not reside with any immediate family members, and does not
appear to have any employment that would require her to remain in the United States. Nor does
she appear to have any permanent ties to any particular location in the United States. As such, the
Government respectfully submits that the defendant will not be able to meet her burden of
overcoming the presumption of detention, because there are no bail conditions that could
reasonably assure the defendant's continued appearance in this case.
In particular, home confinement with electronic monitoring would be inadequate to
mitigate the high risk that the defendant would flee, as she could easily remove a monitoring
device. At best, home confinement with electronic monitoring would merely reduce her head start
should she decide to flee. See United States V. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1
8
EFTA00018513

=== Page 10 ===
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 10 of 10
(E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because
home detention with electronic monitoring "at best
limits a fleeing defendant's head start");
United States V. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002)
(same); see also United States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal.
Feb. 2018) (same); United States V. Anderson, 384 F. Supp. 2d 32, 41 (D.D.C. 2005) (same).
CONCLUSION
As set forth above, the defendant is an extreme risk of flight. The Government respectfully
submits that the defendant cannot meet her burden of overcoming the statutory presumption in
favor of detention. There are no conditions of bail that would assure the defendant's presence in
court proceedings in this case. Accordingly, any application for bail should be denied.
Dated: New York, New York
July 2, 2020
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
alison r. me
By:
Assistant United States Attorneys
(212) 637-2225
9
EFTA00018514


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=== Page 1 ===
Event: Epstein Oral Argument-- Second Circuit
Start Date: 2019-02-06 15:00:00 +0000
End Date: 2019-02-06 17:00:00 +0000
Organizer:
)
Class: X-PERSONAL
Date Created: 2019-01-09 19:42:39 +0000
Date Modified: 2019-01-09 19:42:39 +0000
Priority: 5
DTSTAMP: 2019-01-09 19:14:52 +0000
Attendee:
(USANYS)
i
Alarm: Display the following message 15m before start
Reminder
EFTA00019517


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=== Page 1 ===
From:
To:
Subject: FW: Press Coverage re Op Stolen Globe/Epstein
Date: Tue, 26 Jan 2010 17:34:37 +0000
Importance: Normal
Attachments: ex-epstein-worker-faces.pdf
From
From:
C. (USAFLS)
Sent: Tuesday, January 26, 2010 10:20 AM
Subject: Press Coverage re Op Stolen Globe/Epstein
I have suspicions about who tipped off the press given my recent back and forth with some of the plaintiffs'
attorneys, but in any event, this appeared in this morning's Palm Beach Post.
Can we set up the meeting with the AUSAs in California and New Mexico some time soon?
<<ex-epstein-worker-faces.pdf>>
Thank you
Assistant U.S. Attorney
500 E. Broward Blvd, 7th Floor
Ft Lauderdale, FL 33394
954-660-5946
EFTA00019176


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c7: images
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=== Page 1 ===
2019-05665
Item 2
EFTA00018736

=== Page 2 ===
NCRBM 531.01 *
INMATE HISTORY
*
04-29-2020
PAGE 001 OF 001 *
QUARTERS
*
09:22:47
REG NO..: 76318-054 NAME....: EPSTEIN, JEFFREY EDWARD
CATEGORY: QTR
FUNCTION: PRT
FORMAT:
FCL ASSIGNMENT DESCRIPTION
START DATE/TIME STOP DATE/TIME
(b)(7)(A)
NYM
Z04
HOUSE Z/RANGE 04/BED
AD
08-10-2019 0734 08-10-2019 0736
(b)(7)(E)
NYM
Z04
HOUSE Z/RANGE 04/BED
206L AD
07-29-2019 1221 08-10-2019 0747
NYM
H01 001L
HOUSE H/RANGE 01/BED
001L
07-23-2019 0324 07-29-2019 1221
NYM
Z05 124LAD
HOUSE Z/RANGE 05/BED
124L AD
07-10-2019 1526 07-23-2019 0324
NYM
H01 001L
HOUSE H/RANGE 01/BED
001L
07-08-2019 1803 07-10-2019 1526
NYM
Z02 201LAD
HOUSE Z/RANGE 02/BED
201L AD
07-08-2019 1749 07-08-2019 1803
NYM
Z02 201LAD
HOUSE Z/RANGE 02/BED
201L AD
07-07-2019 1920 07-08-2019 0920
NYM
E06 547U
HOUSE E/RANGE 06/BED
547U
07-06-2019 2136 07-07-2019 1920
NYM
R01 001L
HOUSE R/RANGE 01/BED
001L
07-06-2019 2124 07-06-2019 2136
G0000
TRANSACTION SUCCESSFULLY COMPLETED
EFTA00018737

=== Page 3 ===
2019-05665
Item 3
EFTA00018738

=== Page 4 ===
PP10
NCRBM 535.07 *
CIM CLEARANCE AND SEPARATEE DATA
*
04-29-2020
PAGE 001 OF 001 *
*
09:20:18
REGISTER NO: 76318-054 NAME: EPSTEIN, JEFFREY EDWARD
REGISTER
FIRST
ARS ARS
ARS
ARS QTR
NUMBER LAST NAME
NAME
FCL ASSIGN
DATE
TIME ASSIGN
76318-054 EPSTEIN
JEFFREY NYM DEATH
08-10-2019 0736
*****
FOI EXEMPT
P0011
THIS INMATE HAS NO CMC ASSIGNMENTS
https://bop.tep.doj.gov9049/SENTRY/J1PPG20.do|4/29/20209:21:09 AM]
EFTA00018739

=== Page 5 ===
2019-05665
Item 4
EFTA00018740

=== Page 6 ===
NCRBM
*
INMATE DISCIPLINE DATA
*
04-29-2020
PAGE 001 OF 001 *
CHRONOLOGICAL DISCIPLINARY RECORD
*
09:21:56
REGISTER NO: 76318-054 NAME..: EPSTEIN, JEFFREY EDWARD
FUNCTION...: PRT
FORMAT: CHRONO
LIMIT TO
MOS PRIOR TO 04-29-2020
G5463
NO ENTRIES EXIST IN CHRONOLOGICAL LOG FOR TIME PERIOD REQUESTED
EFTA00018741

=== Page 7 ===
2019-05665
Item 6
EFTA00018742

=== Page 8 ===
PPG0
NCRBM 600.00 *
SECURITY/DESIGNATION
*
04-29-2020
PAGE 001 OF 001 *
DATA
*
09:25:22
REGNO:
76318-054
NAME: EPSTEIN, JEFFREY EDWARD
ORG:
RC/SEX/AGE: W/M/66 FORM D/T:
RES: NEW YORK, NY 10021
OFFN/CHG..: SEX TRAFFICKING CONSP.
SEX TRAFFICKING OF MINORS
CUSTODY..:
BIL:
CITIZENSHP: UNITED STATES OF AMERICA
CIM CONS.:
USM:
JUDGE....:
RECFACL/PGM:
VOLSUR:
VS DT/LOC:
MOS REL:
SEVERITY:
CHP/CHS/S:
VIOLENCE:
ESCAPES.:
DETAINER.:
AGE:
EDUC LV:
HGC:
DRUG/ALC.:
TOTAL:
SEC LVL:
PUB SAFTY:
CAR MD/MH:
OMDT REF:
CCM RMKS.:
P5110
DESIGNATION RECORD DOES NOT EXIST FOR THIS INMATE
https://bop.tep.doj.gov:9049/SENTRY/J1PPG00.dol4/29/20209:25:36 AM]
EFTA00018743

=== Page 9 ===
PPG6
NCRBM 606.00 *
MALE CUSTODY CLASSIFICATION FORM
*
04-29-2020
PAGE 001 OF 001
09:25:54
(A) IDENTIFYING DATA
REG NO..: 76318-054
FORM DATE:
ORG:
NAME....: EPSTEIN, JEFFREY EDWARD
CR HX PT:
MGTV:
PUB SFTY:
MVED:
(B) BASE SCORING
DETAINER:
SEVERITY :
MOS REL.:
CRIM HIST SCORE:
ESCAPES.:
VIOLENCE :
VOL SURR:
AGE CATEGORY...:
EDUC LEV:
DRUG/ALC ABUSE.:
(C) CUSTODY SCORING
TIME SERVED.....:
PROG PARTICIPAT:
LIVING SKILLS...:
TYPE DISCIP RPT:
FREQ DISCIP RPT.:
FAMILY/COMMUN..:
--- LEVEL AND CUSTODY SUMMARY ---
BASE CUST VARIANCE SEC TOTAL SCORED LEV MGMT SEC LEVEL CUSTODY CONSIDER
P5154
CUSTODY CLASSIFICATION RECORD DOES NOT EXIST FOR THIS INMT
https://bop.tep.doj.gov9049/SENTRY/J1PPG60.do[4/29/20209:26:06 AM]
EFTA00018744

=== Page 10 ===
2019-05665
Item 7
EFTA00018745

=== Page 11 ===
NCRBM 535.03 *
INMATE PROFILE
*
04-29-2020
PAGE 001 OF 001
09:23:16
76318-054
REG
REGNO: 76318-054
FUNCTION: PRT DOB/AGE.: 01-20-1953 / 66
NAME.: EPSTEIN, JEFFREY EDWARD
R/S/ETH.: W/M/O
WALSH: YES
RSP..: NYM-NEW YORK MCC
MILEAGE.: 5 MILES
PHONE:
FAX:
ARS ASSIGNMENT..: DEATH
FBI NO..:
ARS DATE/TIME... : 08-10-2019/0736
INS NO..:
PROJ REL METHOD: UNKNOWN
SSN.....:
PROJ REL DATE..: UNKNOWN
PSYCH: NO
DETAINER: NO
CMC..: NO
RELEASE DESTINATION
AGENCY
:
DST ASSIGNMENT
ADDRESS
OFFN/CHG RMKS: SEX TRAFFICKING CONSP.
OFFN/CHG RMKS: SEX TRAFFICKING OF MINORS
FACL CATEGORY
CURRENT ASSIGNMENT
EFF DATE
TIME
NYM
ADM-REL
DEATH
DEATH
08-10-2019 0736
NYM CARE LEVEL CARE1-MH
CARE1-MENTAL HEALTH
07-08-2019 0934
NYM
CASE MGT
CFSA
CERT FOOD SINCERITY APPROVAL
07-19-2019 1209
NYM
EDUC INFO
GED UNK
GED STATUS UNKNOWN
07-06-2019 2124
NYM
FIN RESP
UNASSG
FINANC RESP-UNASSIGNED
07-06-2019 2124
NYM
RELIGION
UNKNOWN
RELIGION UNKNOWN
07-06-2019 2124
G0000
TRANSACTION SUCCESSFULLY COMPLETED
EFTA00018746


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c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Fwd: US V Epstein
Date: Sun, 11 Aug 2019 00:26:32 +0000
Begin forwarded message:
From:
(USANYS)"
Date: August 10, 2019 at 7:54:42 PM EDT
To:
)"
Cc:
(USANYS)"
(USANYS)"
)"
)"
(USANYS)"
(USANYS)"
Subject: Re: US V Epstein
I am looping in
and
on this question. Have you guys ever dealt with an issue like this?
Sent from my iPhone
On Aug 10, 2019, at 7:47 PM,
)
wrote:
Per the below, Epstein's counsel has asked to have a pathologist at the autopsy (and whether it can be delayed
until they're able to arrange for that. Anyone I can point them toward on that issue?? This seems way outside
our lane but not sure who else they could ask. Thanks and sorry for the unusual question.
Begin forwarded message:
From: "Miller,
"
Date: August 10, 2019 at 19:34:37 EDT
To:
)"
,
"Martin G. Weinberg"
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Thanks for being available today and for getting the wheels turning for an investigation into how he died.
On a related note, we are hearing that Jeffrey's autopsy may occur tomorrow morning. We would like to
have a pathologist present for his autopsy and cannot line up someone on such short notice. Is there any
way to push the autopsy off until Tuesday to give us time to do that?
Mike
EFTA00019339

=== Page 2 ===
From:
Sent: Saturday, August 10, 2019 7:31 PM
To: Miller,
>; ; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
)
Subject: RE: US V Epstein
Mike, Marty, Reid,
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a
brief note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we
will continue to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the
investigations of these events will be thorough and swift.
respectfully,
EFTA00019340


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
USANYS)"
Subject: Fwd: Jeffrey Epstein, Blackmail and a Lucrative 'Hot List' - The New York Times
Date: Sun, 01 Dec 2019 23:33:57 +0000
With apologies, I suppose I'm the millionth person to have sent this to you.
>
https://www.nytimes.com/2019/11/30/business/david-boies-potinger-jeffrey-epstein-videos.html
>
EFTA00020442


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=== Page 1 ===
LLC STATEMENT IN SUPPORT
OF REGISTRATION
HYPERION AIR, LLC is a limited liability company of a United States Citizen and is eligible to
register aircraft in its name. In this regard, we make the following representations:
Accepted CK Sep/06/2013
1. The full name of the Applicant LLC is HYPERION AIR, LLC (the "LLC").
2. The jurisdiction in which the LLC is lawfully organized is the United States Virgin Islands.
3. The effective date of the LLC is October 19, 2012.
4. The name of each of the sole Member of the LLC and the type of entity of the sole Member (i.e.,
individual, corporation, partnership, etc.) is:
U.S. CITIZENSHIP
NAME
TYPE OF ENTITY
VERIFICATION
Jeffrey E. Epstein
Individual
YES X NO
5. The LLC is managed by a Manager.
6. The managers, members or officers of this LLC may act independently YX N
7. The name of the sole Manager of the LLC and the type of entity of the sole Manager (i.e., individual,
corporation, partnership, etc.) is:
U.S. CITIZENSHIP
NAME
TYPE OF ENTITY
VERIFICATION
Lawrence Visoski
Individual
YES X NO
The undersigned certifies that he understands that an LLC is eligible to register aircraft in its name provided that:
(1) at least 2/3rds of the managers or managing members are "U.S. Citizens" within the meaning of 49 U.S.C.
Section 40102(a)(15)(C) and:
(2) at least 75% of the voting interest or units is owned or controlled by persons who are "U.S. citizens" or citizens
of one of its possessions; and specifically that AN LLC CANNOT REGISTER AS A NON-CITIZEN
CORPORATION.
If any member of this LLC is not a United States Citizen as defined in 40102(a)(15)(C) an explanation appears below to
support the certification that this LLC is a "U.S. Citizen" as required by 49 U.S.C. Section 40102(a)(15)(C).
The undersigned hereby also certifies that the information given herein is true and correct and meets all citizenship
specifications as required by the Federal Aviation Administration.
HYPERION By AIR, LLC
242 Lawrence Visoski
Manager
EFTA00017879

=== Page 2 ===
EETA000
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2013 AUG 13 AM 7 39
OKLAHOMA CITY
OKLAHOMA


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c3: VOL00008
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=== Page 1 ===
From:
"
(USANYS)"
To:
"
)"
,
(USANYS)"
Subject: https://www.wsj.com/articles/jeffrey-epstein-palm-beach-home-to-be-demolished-11604352533
Date: Tue, 03 Nov 2020 15:54:42 +0000
FWIW.
EFTA00019147


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c3: VOL00008
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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
,
(USANYS)"
i
(USANYS)"
Cc:
)"
(USANYS)"
,
)"
Bcc: "USAHUB-USAJournal111"
Subject: FW: Opposition to Maxwell GJ Motion
Date: Mon, 22 Feb 2021 21:51:14 +0000
Embedded: FW:_Opposition_to_Maxwell_GJ_Motion.msg
Sender:
Subject: FW: Opposition to Maxwell GJ Motion
Message-Id:
<BN3P110MB03399F3DD41F1635686BC5CE92819@BN3P110MB0339.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
To:
Cc:
Cc:
Cc:
EFTA00018707


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c7: images
c0:
=== Page 1 ===
From:
To:
Bcc:
Subject: RE: Question
Date: Sat, 30 Jan 2021 04:11:24 +0000
Embedded: RE: Question.msg
Sender:
Subject: RE: Question
Message-Id:
<BN3P110MB02896A7D7196B40ECCB60E9AB3B89(@BN3P110MB0289.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00019196


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: MCC
Date: Sat, 16 Nov 2019 01:47:03 +0000
No doubt you've seen that the NY Post has an article this evening headlined: "Epstein jail guards had been
offered plea deal but declined."
Sent from my iPhone
EFTA00017910


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=== Page 1 ===
Event: Call with FCA (Epstein)
Start Date: 2019-12-06 15:00:00 +0000
End Date: 2019-12-06 15:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-12-03 23:29:51 +0000
Date Modified: 2019-12-03 23:29:51 +0000
Priority: 5
DTSTAMP: 2019-12-03 18:33:07 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00018129


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c3: VOL00008
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 329 Filed 08/25/21 Page 1 of 1
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/25/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
Defendant submitted a letter on August 18 informing the Court about disruptions of
attorney-client video teleconferences. Dkt. No. 319. After conferring with MDC Legal, the
Government responded on August 23. Dkt. No. 326. According to the Government and MDC
Legal, the Defendant's difficulties in communicating with her counsel via video teleconference
have been resolved, and the Government's letter sufficiently addresses her other requests. The
Court finds MDC Legal's assurance that Defendant's communications have not been interfered
with, recorded, or listened to sufficient. No further application for relief was made in
Defendant's August 24 reply. Dkt. No. 327. The Court remains confident that Ms. Maxwell is
fully able to communicate with her defense counsel and to prepare for trial. If Defendant
experiences further issues in communicating with her counsel, she should promptly notify the
Court after conferring in good faith with the Government and MDC Legal.
SO ORDERED.
Dated: August 25, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
EFTA00017848


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=== Page 1 ===
From:
To:
Cc:
Subject: Additional discovery requests
Date: Mon, 02 Mar 2020 19:21:25 +0000
Attachments: Response_to_1-24-20_letter_from_the_Government.pdf
Hello
Attached is a letter from Noel's counsel requesting additional discovery. Take a look at items 1-13. Does the FBI
CURRENTLY have any notes, reports, or information of any sort responsive to those items? We are NOT asking you to do
any additional investigation. Give me a call to discuss.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
Fax:
EFTA00018548


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Tentative: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:20:34 +0000
Importance: Normal
Attachments: unnamed
EFTA00017899


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=== Page 1 ===
From:
"
)"
To:
d
i
,
Cc:
"
)"
(USANYS)"
Subject: Maxwell
Date: Wed, 02 Dec 2020 15:35:25 +0000
Attachments: 127128077929.pdf
,
, and
,
Please see the attached Order from Judge Nathan, which directs MDC legal to file a letter with the Court by
Friday. Are you available for a call today to discuss?
Thank you,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019928


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From:
(USANYS)"
To:
"
(USANYS)"
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: NEW YORK TIMES; Epstein
Date: Mon, 08 Jul 2019 16:29:17 +0000
Importance: Normal
Inline-Images: image001.jpg; image002.jpg
Nude Photos of Underage Girls Seized From Jeffrey
Epstein Mansion
The prosecutors are seeking to detain the financier while he awaits trial on sexual trafficking charges, saying he
is a flight risk.
U.S. v. Jeffrey Epstein
THE CHARGED
AND PALM
IF YOU RECOGNIZE THIS PERSON YOU MAY
BE A VICTIM, PLEASE CALL THE
1-800-CALL FBI
July 8, 2019
Investigators seized nude photographs of underage girls from the Manhattan townhouse of Jeffrey Epstein
as part of a new investigation into allegations he exploited dozens of minors for sex, prosecutors revealed
on Monday.
That detail was mentioned by federal prosecutors on Monday as they unsealed an indictment charging Mr.
Epstein with sex trafficking and made an appeal to other women who may have been abused by him to
come forward.
"They deserve their day in court and we are proud to stand up for them by bringing this indictment," the
United States attorney in Manhattan, Geoffrey S. Berman, said.
Mr. Epstein, 66, is accused of engaging in sex acts with dozens of vulnerable minors, some as young as 14,
during naked massage sessions, then paying them hundreds of dollars in cash. He also asked some of the
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=== Page 2 ===
girls to recruit other underage girls, the indictment said.
"In this way, Epstein created a vast network of underage victims for him to sexually exploit in locations
including New York and Palm Beach," the indictment said.
Mr. Berman's decision to seek an indictment in Manhattan was an implicit rebuke to the decision by
prosecutors in Miami in 2008 to enter an agreement with Mr. Epstein that allowed him to avoid federal
prosecution and a possible life sentence.
Under that deal, Mr. Epstein pleaded guilty to state prostitution charges and spent about a year in a Palm
Beach jail. He was permitted to leave the facility six days a week to work.
Mr. Berman made it clear his office was not bound by the agreement, which was overseen by Alexander
Acosta, then the United States attorney in Miami who is now President Trump's secretary of labor.
"That agreement, by its terms, only binds the Southern District of Florida," Mr. Berman said.
The agreement has been examined in a series of reports in The Miami Herald and is being challenged in
court. A federal judge ruled earlier this year Mr. Epstein's accusers should have been consulted about the
deal before it was signed.
The indictment unsealed in Manhattan on Monday said that from 2002 to 2005 Mr. Epstein and his
employees engaged in a sex trafficking scheme, bringing underage girls to his Upper East Side mansion
and his palatial compound in Palm Beach, Fla., to engage in sex acts with him.
The indictment said Mr. Epstein used employees and assistants to arrange sexual rendezvous with at least
one girl at his New York residence and two at his home in Palm Beach.
Mr. Epstein is accused of having the girls perform nude massages, at which point he would masturbate and
touch their genitals with his hands or with sex toys.
The girls were paid hundreds of dollars in cash for each encounter and, once recruited, were asked to
return to the mansion several times, where they were abused again, the indictment said. Mr. Epstein, the
court documents read, "created a similar network of minor girls to victimize" in Florida.
"This conduct, as alleged, went on for years and involved dozens of young girls, some as young as 14,"
Mr. Berman said. "The alleged behavior shocks the conscience."
[Read the indictment.]
The charges unsealed Monday by the Southern District of New York signal a prosecution that some of his
accusers have been awaiting for years.
Accusations of pedophilia and sexual predation have dogged Mr. Epstein for decades. And now, in the
#MeToo era, his case has been held up as a prime example of insulated, powerful men avoiding
accountability.
For more than a decade, Mr. Epstein, a hedge fund manager, avoided a lengthy prison sentence, largely
because of the agreement his lawyers struck with federal prosecutors in 2008.
Mr. Epstein's social circle is filled with other high-profile connections, including to former President Bill Clinton, Prince
Andrew of Britain and a host of others.
In 2002, Mr. Trump described Mr. Epstein as "a terrific guy."
"He's a lot of fun to be with," Mr. Trump told New York Magazine. "It is even said that he likes beautiful
women as much as I do, and many of them are on the younger side."
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On Saturday, F.B.I. agents and New York Police Department officers used a crow bar to force open the wooden doors of
Mr. Epstein's East 71st Street mansion.
The charges unsealed Monday mirror those that federal prosecutors had prepared in Miami against Mr.
Epstein more than a decade ago. In 2005, law enforcement officials there investigated Mr. Epstein after the
parents of one of his accusers reported an incident to the police.
As first reported in The Miami Herald last year, prosecutors had prepared a 53-page indictment accusing
Mr. Epstein of being a sexual predator. But those charges were shelved in 2008 after an eleventh-hour deal
was reached between the United States attorney's office in Miami and Mr. Epstein's lawyers.
The plea agreement granted Mr. Epstein immunity from federal prosecution and let him plead guilty to two
prostitution charges in state court. Federal prosecutors arranged for the plea deal to be kept secret from Mr.
Epstein's accusers until it was finalized in court.
In April, a federal judge ruled that prosecutors had violated the law in offering the plea agreement without
informing Mr. Epstein's accusers. The Justice Department also opened a probe into the incident in
February.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
Mobile:
Press Office:
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From:
)"
To:
Cc:
)"
,
)"
Subject: FW: Continued investigation into possible collaborators of Jeffrey Epstein
Date: Tue, 17 Sep 2019 21:19:18 +0000
Attachments: 9-17-19_Letter_to_AUSA
re_Epstein.pdf
Hi guys,
Would one of you please download the files referenced in the below email and save them on the Epstein share?
Thanks,
From
Sent: Tuesday, September 17, 2019 2:05 PM
To:
)
Cc: Clara Moran
Subject: Continued investigation into possible collaborators of Jeffrey Epstein
Ms.
Please see the attached correspondence from Chief Deputy Attorney General Clara Moran.
You can access the materials referenced in the letter by following this link and entering this password:
NMAG files
Password (without quotes) -- "7e4DzyfvYC"
Note that this link will expire on October 16, 2019.
A CD containing this correspondence and the attached materials will also be arriving shortly via U.S. Mail.
Have a good day.
Assistant Attorney General
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From:
"
(USANYS)"
To:
)"
)"
,
)"
Cc:
(USANYS)"
(USANYS)"
(USANYS) [Contractor]"
Subject: Epstein
Date: Wed, 11 Dec 2019 15:34:32 +0000
FWIW/FYI - Julie Brown is hearing that we're unsealing four indictments against co-conspirators next week.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
I
Press Office:
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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
REPLY MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT,
MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE
OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND
TO DISMISS COUNTS FIVE AND SIX
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue New
York, NY 10022
Phone: 212-957-7600
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
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=== Page 2 ===
TABLE OF CONTENTS
TABLE OF CONTENTS
ii
TABLE OF AUTHORITIES
iii
TABLE OF EXHIBITS
V
Factual Background
1
Argument
1
I.
The Government's violation of the Fourth Amendment requires suppression
1
A.
Maxwell has standing.
1
B. There is no good faith.
5
C. The government's inevitable discovery doctrine fails.
5
II.
The Government's violation of Martindell requires suppression.
7
III. The Government's violation of the Fifth Amendment requires suppression
10
IV. The Court should hold an evidentiary hearing
13
CONCLUSION
13
Certificate of Service
15
ii
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=== Page 3 ===
TABLE OF AUTHORITIES
Cases
Appeal of Hughes, 633 F.2d 282 (3d Cir. 1980)
2
Carpenter V. United States, 138 S. Ct. 2206 (2018).
2,3
Doe V. Indyke, Case No., 20-cv-00484 (S.D.N.Y.)
6
Giuffre V. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018)
6
Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49
(S.D.N.Y. 1988)
1
Raheem V. Kelly, 257 F.3d 122 (2d Cir. 2001)
9
Refco Grp. Ltd., LLC V. Cantor Fitzgerald, L.P., No. 13 CIV. 1654 RA HBP, 2014 WL 5420225
(S.D.N.Y. Oct. 24, 2014)
2
United States V. Cortina, 630 F.2d 1207 (7th Cir. 1980)
5
United States V. Heath, 455 F.3d 52 (2d Cir. 2006)
7
United States V. Lavender, 583 F.2d 630 (2d Cir. 1978)
2,4
United States V. Leon, 468 U.S. 897 (1984)
5
United States V. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)
12
United States V. Stein, 541 F.3d 130 (2d Cir. 2008)
10
United States V. Stokes, 733 F.3d 438 (2d Cir. 2013)
5,6,7
United States V. Taylor, 745 F.3d 15 (2d Cir. 2014)
12
US Bank Nat. Ass 'n V. PHL Variable Ins. Co., No. 12 CIV. 6811 CM JCF, 2012 WL 5395249
(S.D.N.Y. Nov. 5, 2012)
2
iii
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Other Authorities
Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and
Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020)
11
Rules
Fed. R. Civ. P. 24(b)
4
Fed. R. Civ. P. 26(c)
13
Fed. R. Crim. P. 17(c)
4
Constitutional Provisions
U.S. CONST. amend. IV
1
U.S. CONST. amend. V
1,9
iv
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=== Page 5 ===
TABLE OF EXHIBITS
EXHIBIT A: Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations
by Law Enforcement" or, In the Alternative, to Stay Proceedings. Giuffre V. Maxwell, No. 15-cv-
07433-RWS, Apr. 18, 2016
EXHIBIT B: Giuffre V. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016
V
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Ghislaine Maxwell moves under the Fourth Amendment, Martindell V. Int'l Tel. & Tel.
Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the
government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to
dismiss Counts Five and Six, which are the fruits of that unlawful subpoena.
Factual Background
The facts relevant to this Motion are described in Maxwell's Pretrial Motion No. 3 and
the Reply in Support Thereof.
Argument
I. The Government's violation of the Fourth Amendment requires suppression.
The government does not defend the overbreadth of its subpoena, or even respond to
Maxwell's argument. Resp. at 82-95. The government also does not deny that the subpoena
effected both a search and a seizure under the Fourth Amendment. Id.
Instead, the government argues that (1) Maxwell has no standing to challenge the
subpoena; (2) the government acted in good faith; and (3) the government inevitably would have
come to possess the 90,000-sum pages of material it obtained from Boies Schiller.
The facts and law belie the government's claims.
A. Maxwell has standing.
The government's standing argument boils down to this: Maxwell cannot challenge the
search because the material was in the possession of a third party and Maxwell lacked a
reasonable expectation of privacy. Resp. at 84-86. This argument fails.
Abundant authority holds that when confidential material is in the possession of a third-
party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of
Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988)
(law firm could intervene and join motion to quash grand jury subpoena issued to private
1
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=== Page 7 ===
investigation firm). "The governing rule in these circumstances is that the possessor of the
claimed privilege or right may intervene to assert it." Id. (quoting Appeal of Hughes, 633 F.2d
282, 288 (3d Cir. 1980)). See also US Bank Nat. Ass'n V. PHL Variable Ins. Co., No. 12 CIV.
6811 CM JCF, 2012 WL 5395249, at *2 (S.D.N.Y. Nov. 5, 2012) ("A party [has] standing to
challenge a subpoena served on a non-party [when] the moving party assert[s] some right
or privilege personal to it, such as an interest in proprietary, confidential information that would
be disclosed or an interest in maintaining a privilege that would be breached by disclosure."
(citing cases)). In turn, in determining whether there is standing, "[c]ourts should consider
whether the information itself is private, confidential, privileged, or highly sensitive, and not the
form the records take." Refco Grp. Ltd., LLC V. Cantor Fitzgerald, L.P., No. 13 CIV. 1654 RA
HBP, 2014 WL 5420225, at *4 (S.D.N.Y. Oct. 24, 2014).
In United States V. Lavender, the Second Circuit held that while a defendant could not
file an interlocutory appeal of the district court's denial of his motion to quash a third-party
subpoena, he was "free to raise his Fourth Amendment claims via motions to suppress. 583
F.2d 630, 632 (2d Cir. 1978). Since Maxwell never had notice of the subpoena to Boies Schiller,
she is doing here exactly what Lavender allows: filing a motion to suppress.
To be sure, if the government were right-that the mere fact of a third-party's possession
of property eliminates a defendant's standing-then Carpenter V. United States would have
come out differently, since the defendant's historical cell-site location information was in the
possession of MetroPCS and Sprint. 138 S. Ct. 2206, 2212 (2018). But the United States
Supreme Court rejected application of the third-party doctrine for two reasons, as this Court
should here.
2
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=== Page 8 ===
First, the Court recognized that
[t]here is a world of difference between the limited types of personal information
addressed in Smith and Miller and the exhaustive chronicle of location information
casually collected by wireless carriers today. The Government thus is not asking
for a straightforward application of the third-party doctrine, but instead a significant
extension of it to a distinct category of information.
Id. at 2219. Second, the Court concluded that in "in no meaningful sense" did Carpenter
voluntarily "assume the risk" of "turning over a comprehensive dossier of his physical
movements." Id. at 2220.
The same logic applies here. There is "world of difference between the limited types of
personal information addressed in Smith and Miller and the exhaustive" and personal details
about Maxwell that are contained in Boies Schiller's 90,000 pages of confidential material.
These details include, for example, information about Maxwell's sexual partners, sexual habits,
finances, and much, much more.
Moreover, "in no meaningful sense" did Maxwell voluntarily share this information with
Boies Schiller. Giuffre sued Maxwell, not the other way around. And the defamation claim (the
only claim Giuffre ever asserted against Maxwell, who did not file a counterclaim) had nothing
to do with much of the confidential information Maxwell was forced, over objection, to provide.
Maxwell's motion to dismiss the perjury counts for lack of materiality and her motion for
severance, and the replies in support thereof, explain this in more detail. Maxwell Pre-Trial Mot.
Nos. 4 & 5.
But the point is this: The defamation case should have been extremely narrow, but Boies
Schiller transformed it into something much broader-a proxy prosecution of Epstein and
Maxwell for allegedly trafficking and abusing Giuffre, which then compelled Maxwell, over
objection, to answer irrelevant and highly prejudicial personal questions. None of it was
voluntary.
3
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=== Page 9 ===
In addition to the inapplicability of the third-party doctrine, the government's response
fails to account for two other, dispositive facts proving that Maxwell has a reasonable
expectation of privacy. First, the Protective Order by its terms affords Maxwell a reasonable
expectation of privacy. Mot. 3, Ex. A, 1 3 (defining "CONFIDENTIAL" information as that
which "implicates common law and statutory privacy interests of
Ghislaine Maxwell"
(emphasis added)). What would it say to civil litigants if they could not rely on a court's promise
of confidentiality, at least absent notice and an opportunity to object to any breach of that
promise (which, of course, Maxwell was denied here). See Mot. 3, Ex. A, " 14 (precluding
modification of the Protective Order absent "good cause shown following notice to all parties
and an opportunity for them to be heard").
Second, Martindell affords Maxwell a reasonable expectation of privacy. Martindell, 594
F.2d at 294. In Martindell, the Second Circuit held that "the proper procedure" to obtain
confidential material under a Protective Order, "as the Government should know, was either to
subpoena the deposition transcripts for use in a pending proceeding such as a grand jury
investigation or trial, in which the issue could be raised by motion to quash or modify the
subpoena, [Fed. R. Crim. P. 17(c)] or to seek permissive intervention in the private action
pursuant to [Fed. R. Civ. P. 24(b)], for the purpose of obtaining vacation or modification of the
protective order." Id. (emphasis added)). By affording Maxwell a right to notice and an
opportunity to be heard, Martindell makes clear that, having been denied those rights when the
subpoena was first issued, Maxwell has standing to challenge the government's conduct now.
Id.; see Lavender, 583 F.2d at 632.
4
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=== Page 10 ===
B. There is no good faith.
The rebuttal to government's good faith claim is simple: There can be no good faith
when the government willfully and intentionally misleads the court into authorizing its search.
As the United States Supreme Court held in United States V. Leon,
Suppression remains an appropriate remedy if the magistrate or judge in issuing
a warrant was misled by information in an affidavit that the affiant knew was false
or would have known was false except for his reckless disregard of the truth.
468 U.S. 897, 923 (1984).
Here, as explained in Maxwell's due process motion to suppress and the reply in support
thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order
and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the
government acts in objective bad faith.
C. The government's inevitable discovery doctrine fails.
There are several reasons the government's inevitable discovery argument fails.
First, the inevitable discovery doctrine is an exception to the Fourth Amendment's
exclusionary rule. United States V. Stokes, 733 F.3d 438, 442-43 (2d Cir. 2013) (reversing
district court's denial of motion to suppress, which was based on "the inevitable discovery
doctrine, an exception to the Fourth Amendment's exclusionary rule"). The doctrine has no
applicability when a court exercises its inherent or supervisory authority to suppress evidence
obtained through deliberate government misconduct. The exercise of that authority is meant to
vindicate the dignity of the Court and to deter improper governmental conduct. See United States
V. Cortina, 630 F.2d 1207, 1216 (7th Cir. 1980) ("The need for deterrence of illegal conduct is,
in one sense, greater here than [elsewhere], for [the government's] offense was committed within
the sanctity of the court itself.").
5
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=== Page 11 ===
Second, the government's inevitable discovery doctrine is far too speculative. The
"typical application" of the inevitable discovery doctrine is when "the government seeks to
invoke the doctrine on the basis of standardized, established procedures such as those requiring
inventory searches." Stokes, 733 F.3d at 447. The government's "inevitability analysis in this
case," however, "is predicated on an assessment of the actions that might have been taken by
third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of
the police." Id. "Such an analysis is inherently speculative." Id.
In fact, unlike every other civil case in the Southern District of New York against
Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going
unsealing process in Giuffre V. Maxwell. In the only other active SDNY case against Epstein,
Doe V. Indyke, No. 20-cv-484-JLK, the government intervened and moved to stay discovery,
saying that continued discovery could threaten its case against Maxwell.
By contrast, the government opted not to intervene and stay the unsealing in Giuffre V.
Maxwell. The reason is obvious. Legitimately concerned about the propriety of its conduct in
misleading Chief Judge McMahon and issuing an unconstitutionally overbroad subpoena to
Boies Schiller, the government hoped to hedge its bets by allowing the unsealing process to
unfold so it could make the inevitable discovery argument it now makes. This Court should not
condone such gamesmanship.¹
Third, the government's inevitable discovery argument is far too broad. Even the
government admits that the vast majority of material it obtained from Boies Schiller is not on the
Giuffre V. Maxwell docket and has not been unsealed by Judge Preska. Resp. at 94. In fact, the
government's response appears to concede that its inevitable discovery argument is limited to
1 As the government recognizes, Judge Preska recognized this possibility, but deferred to this
Court on the question since it is presiding over the criminal case. Resp. at 94 n.41.
6
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=== Page 12 ===
Maxwell's two deposition transcripts, Resp. at 94 & n.41. And as to Count 6 in particular
(alleging perjury in the July 2016 deposition), the government concedes, as it must, that Judge
Preska has refused to unseal all of the testimony charged in the indictment, except one question
and one answer. Resp. at 94 n.41. The government offers no explanation for how it inevitably
would have obtained all 90,000 pages of material from Boies Schiller when the two deposition
transcripts don't even total 1,000 pages.
Fourth, the government misunderstands the burden of proof. The government tries to
fault Maxwell for seeking "suppression of all evidence [it] obtained pursuant to the subpoena,"
calling this a "windfall." Resp. at 95. But it's the government's burden to prove the applicability
of the inevitable discovery exception. Stokes, 733 F.3d at 444 (inevitable discovery doctrine
applies only "if the government can prove that the evidence would have been obtained inevitably
without the constitutional violation") (rejecting government's inevitable discovery claim). The
government must explain why Maxwell isn't entitled to this remedy, not the other way around.
The government has fallen far, far short of meeting its burden, if only because it offers no
argument-on the facts or the law-for how it might have inevitably discovered more than
89,000 pages of material that hasn't been and won't be unsealed by Judge Preska. This Court
should have no confidence, much less a "high level of confidence, that each of the contingencies
necessary to the legal discovery of the contested evidence would be resolved in the government's
favor." United States V. Heath, 455 F.3d 52, 55 (2d Cir. 2006) (articulating inevitable discovery
standard).
The inevitable discovery doctrine does not apply.
II. The Government's violation of Martindell requires suppression.
The government ignores the primary argument Maxwell made in her Motion: The
government circumvented Martindell, and deprived Maxwell of due process, by securing a
7
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=== Page 13 ===
modification of the Protective Order in an ex parte hearing (chock full of misrepresentations)
without first providing Maxwell notice and an opportunity to be heard. Mot. No. 11, at 11-15.
The government offers no response to this fundamental point-Martindell demands notice and
an opportunity to be heard; Maxwell received neither. Resp. at 76-81.
Now, in an audacious request, the government argues this Court cannot evaluate the
propriety of Chief Judge McMahon's analysis of Martindell, because Judge McMahon is a co-
equal judge who exercised her sound discretion. Resp. at 81 & n.37. Were the government's
unsupported argument correct, though, it would mean that Maxwell will never have an
opportunity to challenge the subpoena under Martindell, as that case and due process require.
The government is not right.
This Court does not owe deference to Judge McMahon's decision, for at least three
reasons. First, Maxwell never was given the chance to oppose the government's request, so due
process demands that she be given that chance now. Second, Chief Judge McMahon did not
possess all the relevant facts because the government improperly concealed them from her. To
the contrary, the government misled Judge McMahon about its contacts with Boies Schiller and
the origins of its investigation, facts that were central to Judge McMahon's decision to modify
the Protective Order and authorize the subpoena. Mot. No. 3 & Reply in Support Thereof. Third,
this Court is not tasked with deciding whether the Protective Order should be modified or even
questioning the correctness of Judge McMahon's modification. This Court is deciding a different
question entirely-whether the government's violation of Martindell requires suppression.
As to remedy, the government says that no case addresses whether suppression is proper
for a Martindell violation. Fair enough. Resp. at 81.
8
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=== Page 14 ===
But that's doubtless because that law has been clear for forty-two years that the
government can modify a civil Protective Order and then subpoena confidential material only
after notice to the real party in interest and an opportunity to respond. Martindell, 594 F.2d at
294 (Martindell decided in 1979). The proper procedure for modifying a civil Protective Order at
the government's request, in other words, is the one that affords due process. U.S. CONST.
amend. V.
That no case has addressed the remedy for a Martindell violation is evidence only of (1)
the government's prior compliance with Martindell (which should, of course, be expected), or
(2) a criminal defendant having not raised the issue before. In this case, however, (1) the
government violated Martindell, and (2) Maxwell seeks suppression as a sanction.
Suppression is the proper remedy for at least two reasons. First, at its heart, Martindell is
grounded in due process principles, and the government's conduct here violated Maxwell's right
to due process. See U.S. CONST. amend. V. The essence of due process is notice and an
opportunity to be heard. Martindell guaranteed Maxwell notice and an opportunity to be heard,
594 F.2d at 294, as did the Protective Order, Mot. 3, Ex. A, 14. But Maxwell had no idea that
the Giuffre Protective Order had been modified behind her back until she was indicted and the
government disclosed the 90,000 pages of material it obtained from Boies Schiller. 2 The
government's due process violation warrants suppression. E.g., Raheem V. Kelly, 257 F.3d 122,
135 (2d Cir. 2001) (suppression for due process violation).
Second, because the government violated Martindell not only by denying Maxwell notice
and an opportunity to be heard, but also by affirmatively misleading Chief Judge McMahon,
2 To this day, Judge Preska-who is presiding over the Giuffre action since Judge Sweet's
passing and is addressing the Protective Order on a daily basis as the parties brief what material should be
unsealed-apparently does not know the Protective Order was modified.
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=== Page 15 ===
suppression is proper under this Court's inherent and supervisory authority. Mot. No. 3 & Reply
in Support Thereof.
III. The Government's violation of the Fifth Amendment requires suppression.
The government offers three responses to Maxwell's Fifth Amendment argument. None
is persuasive.
The government's first response is to deny any state action. Resp. at 99-100. But as even
the government admits, a private party, like Boies Schiller, is deemed to be an agent of the state
when the government "has provided such significant encouragement, either overt or covert, that
the choice must in law be deemed to be that of the State." Resp. at 99 (quoting United States V.
Stein, 541 F.3d 130, 146 (2d Cir. 2008)). Here, based on the record of the government's contacts
with Boies Schiller in the months before and after Maxwell's depositions, there is at least a
genuine question of fact as to the government's role in encouraging Boies Schiller.
We know that the government contemplated a perjury prosecution of Maxwell, as seen in
the government's newly-disclosed notes from the meeting. Reply ISO Mot. to Suppress, Ex. K, p
5. And if the government is to be believed, there was only one meeting with Boies Schiller, two
months before Maxwell's first deposition. If the government was contemplating a perjury
prosecution before Maxwell even testified, it stands to reason that Boies Schiller and the
government discussed at the February 29 meeting a plan to set a perjury trap for Maxwell.
Indeed, the contemporaneous notes of the February 29 meeting show that Boies Schiller
promised to send the government "depositions," Reply ISO Mot. to Suppress, Ex. J, p 8, and
David Boies later complained about his frustration that the government had not yet charged
10
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Maxwell with perjury.³ There are compelling reasons, therefore, to think the government and
Boies Schiller collaborated and that Boies Schiller's conduct was in part at the government's
behest.
The record in the Giuffre case preceding the first deposition supports this conclusion as
well. Based on Giuffre's claim of an ongoing investigation, Maxwell requested, prior to her
deposition, that Giuffre disclose any alleged "on-going criminal investigation by law
enforcement" or alternatively to stay the action pending completion of any such investigation.
Ex. A. In part, Maxwell needed information concerning any such investigation to assess "the
impact on any 5th Amendment privilege." Ex. A, p 3. The district court declined to afford Ms.
Maxwell the requested relief. Ex. B.
The day before Maxwell's April 2016 deposition, however, Judge Sweet ordered that
"[a]ny materials that [Giuffre] has with respect to any criminal investigations will be turned over
[by Giuffre] except for any statements made by [Giuffre] to law enforcement authority." Ex. B, p
21. Maxwell had in fact served a discovery request on Boies Schiller for any such documents, yet
Giuffre produced no such materials, and the deposition proceeded as scheduled the next day.
In reliance on the Protective Order, which included no exception for any law enforcement
need or subpoena and based on Giuffre's failure to disclose any "ongoing criminal
investigation," Maxwell did not assert her Fifth Amendment privilege against self-incrimination
during that deposition and testified truthfully.
As explained in Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof, the
government has now disclosed several documents "with respect to any criminal investigations"
3 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and
Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020),
https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013-
jmzhl7zdrzdgrbbs7yc6bfnszu-story.html.
11
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=== Page 17 ===
that Giuffre possessed in February and March 2016. Under Judge Sweet's pre-deposition order,
Giuffre should have turned these documents over to Maxwell before the April 2016 deposition.
Giuffre's failure to turn the documents over, despite Judge Sweet's order, is compelling evidence
that Boies Schiller was acting as an agent of the state for Fifth Amendment purposes when
deposing Maxwell. At the very least, the possibility cannot be dismissed out of hand, and an
evidentiary hearing is appropriate.
The government's second argument is that Maxwell waived her Fifth Amendment right.
Resp. at 100. Not so. A waiver is valid only if it is knowingly made. United States V. Taylor, 745
F.3d 15, 23 (2d Cir. 2014). And "knowing" means with full awareness of the nature of the right
being abandoned and the consequences of abandoning it." Id.
Here, Maxwell did not knowingly waive her Fifth Amendment right. She declined to
invoke it based on the protections afforded to her by the Protective Order, and on the
understanding that the government was not actively investigating her. That understanding, as it
turned out, was incorrect, but it was a misunderstanding deliberately encouraged by Boies
Schiller with cooperation from the government. If Boies Schiller had disclosed that material
Judge Sweet ordered them to disclose, Maxwell would have invoked her Fifth Amendment right
and avoided the perjury trap the government and Boies Schiller set for her.
It is for this reason that the government fails in its attempt to distinguish United States V.
Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988). Resp. at 102. The government says that the logic of
Oshatz does not apply because the defendant there had already been indicted whereas here,
Maxwell was deposed "over two years before the Government opened its investigation." Resp. at
100; id. at 102 (noting that the defendant in Oshatz "had already been indicted at the time of his
deposition in a civil case for almost seven months"). Of course, this argument depends on the
12
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=== Page 18 ===
government's claim that its investigation of Maxwell did not start until 2018. But based on the
discovery provided to Maxwell in response to her Pretrial Motion No. 3, we know the
investigation actually began as early as 2016, when two months before Maxwell's first
deposition, Boies Schiller met with the government and pressed an investigation for, among
other things, perjury. This Court should adhere to Oshatz and, as the court there granted the
motion to quash, here it should grant the motion to suppress.
The government's final argument is a red herring. Resp. at 103. Maxwell's argument is
not, and has never been, that a Protective Order cannot be modified. Maxwell agrees that, under
Martindell, and after notice to the real party in interest and an opportunity to be heard,
modification of a Protective Order is appropriate if the government can show "improvidence in
the grant of a Rule 26(c) protective order or some extraordinary circumstance or compelling
need." 594 F.2d at 296. Here, Maxwell was never given notice and an opportunity to be heard,
and Chief Judge McMahon's finding of "extraordinary circumstances" was fatally tainted by the
government's misrepresentations to her about the origins of its investigation.
IV. The Court should hold an evidentiary hearing.
Because there are genuine disputes of material fact, and for the reasons given in
Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof, this Court should hold an
evidentiary hearing.
CONCLUSION
For these reasons, as well as those given in the Motion, this Court should: (1) suppress all
evidence the Government obtained from Boies Schiller and any other evidence derived
therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived
therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this
Motion.
13
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=== Page 19 ===
Dated: March 15, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue New York, NY 10022 Phone:
212-957-7600
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
14
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=== Page 20 ===
Certificate of Service
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the Reply Memorandum of Ghislaine Maxwell in
Support of Her Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to
Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss
Counts Five and Six upon the following:
U.S. Attorney's Office, SDNY
One Saint Andrew's Plaza
New York, NY 10007
s/ Christian R. Everdell
15
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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
July 13, 2021
andy
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
Hanlme
Assistant United States Attorney
RICT FOR THE YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
rev. 02.01.12
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=== Page 1 ===
From:
To:
Subject: Fwd: Metropolitan Correctional Center 'accidentally released' serial bank robber days before
Epstein's death
Date: Thu, 15 Aug 2019 21:22:04 +0000
Sent from my iPhone
Begin forwarded message:
From:
Date: August 15, 2019 at 4:54:20 PM EDT
To:
Subject: RE: Metropolitan Correctional Center 'accidentally released' serial bank robber days before
Epstein's death
Thanks
From:
Sent: Thursday, August 15, 2019 4:34 PM
To:
Subject: Metropolitan Correctional Center 'accidentally released' serial bank robber days before Epstein's death
Metropolitan Correctional Center 'accidentally released' serial bank robber days before Epstein's death
Fox News
By Nicole Darrah
8/15/19
A serial bank robber awaiting sentencing at the Metropolitan Correctional Center in Manhattan was "accidentally
released" from federal custody just days before a series of ignored protocols gave Jeffrey Epstein the opportunity
for his apparent suicide.
Michael Matthews, 58, was told Aug. 7 he was free to leave the New York facility which, in recent days, has come
under fire after Epstein, 66, died from an apparent suicide after being left alone in his cell for hours on Saturday -
despite recently being on suicide watch, and despite protocol requiring otherwise.
Matthews' family told the New York Daily News that a counselor at MCC invited him to their office, where he was
given a card to ride the subway and paperwork to sign to be released. He knew he was awaiting sentencing,
scheduled for Sept. 20, but didn't speak up.
Richard Donoghue, U.S. Attorney for the Eastern District of New York, stated in a letter obtained by Fox News on
Thursday that Matthews — who previously served time for bank robbery - was released, despite being held
"pursuant to a permanent order of detention."
EFTA00019402

=== Page 2 ===
He explains that Matthews was arrested in January after he failed to appear at a halfway house in Brooklyn after
being released from a federal facility in New Jersey. He was charged with escaping custody, and was also charged in
three bank robberies during the time he was supposed to be in the halfway house, according to prosecutors.
"The government is currently seeking additional information about the circumstances prompting the defendant's
pre-sentencing release, and sets forth below those facts that the government has confirmed to date," Donoghue
wrote.
While Matthews surrendered to officials Aug. 12, his release further contributes to the scrutiny surrounding the
MMC - which houses some of the highest-security inmates in the U.S. - following Epstein's death.
Attorney General William Barr vowed on Monday a full investigation into the federal prison. He said he was
"appalled.. and frankly, angry to learn of MCC's failure to adequately secure this prisoner."
"We are now learning of serious irregularities at this facility that are deeply concerning and demand a thorough
investigation."
Epstein, who was found with bruising on his neck in his cell last month, had been taken off suicide watch shortly
before his death, according to a source familiar with the matter. Per protocol, the 66-year-old should've been
checked on every 30 minutes, but before his death had not been physically checked on for "several hours."
Additionally, he didn't have a cellmate on the night of his death.
A lawyer for one of Epstein's former cellmates, Nicholas Tartaglione, a former police officer in New York who
was charged in 2016 with the deaths of four men stemming from an alleged cocaine conspiracy, told Fox News
earlier this week he's had several clients who have been locked up both in New York City's notorious Rikers Island
jail and MCC, and claimed many have said they "would rather be at Rikers."
"That gives you some idea how bad the place is," the lawyer, Bruce Barket said. "At the end of the day, the facility
is run with a bad combination of laziness and cruelty and this is one of the results."
He described conditions at MCC "border on inhumane," and said one day, when Tartaglione woke up, he
discovered that while sleeping he'd rolled onto a rodent, smothering it.
Separately, a representative from the American Federation of Government Employees/Council of Prison Locals
decried the low staff levels at MCC, but also said the issue is a "system-wide crisis in our prison system."
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=== Page 1 ===
From:
(USANYS)"
@usa.doj.gov>
To:
(USANYS)"
Subject: Fwd: update
Date: Mon, 24 Feb 2020 18:29:57 +0000
We can get back to him after we talk to Bobbi.
Sent from my iPhone
Begin forwarded message:
From: Bruce Barket <bbarket@barketepstein.com
Date: February 24, 2020 at 1:19:43 PM EST
To:
@usdoj.gov"
@usdoj.gov>
Subject: update
Good afternoon,
I am writing because my trial which was supposed to begin today has been moved to March 3rd. I asked the Court
(EDNY) for March 4th off so I would be able to attend the status conference for Mr. Tartaglione and I explained briefly
that there was a Curcio issue. That application was denied.
So, I am wondering if you will be requesting more time to continue to review material and presumably get input from
our firm. If so, then it may make sense to adjourn the conference. If you don't need more time, then I may make
another request or ask Judge Karas to help. I don't think there is much else that will be done next week other than
address the Curcio issue.
Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
(516) 745 1500 [P] (516) 745 1245 [F]
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
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=== Page 1 ===
From:
To:
Subject: Civil Division meeting -- in view of Epstein papers, should we push to later or postpone?
Date: Fri, 12 Jul 2019 18:16:24 +0000
Importance: Normal
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Expert Witness
Date: Wed, 28 Oct 2020 18:24:24 +0000
Embedded: RE:_Expert_Witness.msg
Sender:
Subject: RE: Expert Witness
Message-Id:
Recipient:
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=== Page 1 ===
From:
"
To:
,
Subject: RE: MCC/Epstein Meeting
Date: Wed, 14 Aug 2019 20:44:40 +0000
Yes, thanks.
From:
Sent: Wednesday, August 14, 2019 4:44 PM
To:
is
Subject: RE: MCC/Epstein Meeting
Hey guys,
I assume you've probably spoken with Geoff/the brass about this, but just want to confirm this is ok?
Thanks,
From:
Sent: Wednesday, August 14, 2019 1:14 PM
To:
is
Subject: MCC/Epstein Meeting
Hey guys,
Geoff would like to meet 12-2pm tomorrow after the MCC visit with the brass, you two, the MCC team, and the folks
visiting from main justice/FBI/IG
(
etc.)
We'll be in the 8th floor library.
Thanks!
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=== Page 1 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
Plaintiff,
No. 15 Civ. 7433 (LAP)
-against-
MEMORANDUM & ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Court has reviewed Defendant Ghislaine Maxwell's letter
requesting reconsideration of the Court's July 23, 2020, decision
to unseal (1) the transcripts of Ms. Maxwell's and Doe 1's
depositions, and (2) court submissions excerpting from, quoting
from, or summarizing the contents of the transcripts. (See dkt.
no. 1078.)
Ms. Maxwell's eleventh-hour request for reconsideration is
denied. As Ms. Maxwell acknowledges in her letter, reconsideration
is an "extraordinary remedy." In re Beacon Assocs. Litig., 818 F.
Supp. 2d 697, 701 (S.D.N.Y. 2011) (quoting In re Health Mgmt. Sys.
Inc. Sec. Litig., 113 F. Supp. 2d 613, 614 (S.D.N.Y. 2000)). Such
motions "are properly granted only if there is a showing of: (1)
an intervening change in controlling law; (2) the availability of
new evidence; or (3) a need to correct a clear error or prevent
manifest injustice." Drapkin V. Mafco Consol. Grp., Inc., 818 F.
Supp. 2d 678, 696 (S.D.N.Y. 2011). "A motion for reconsideration
1
EFTA00018294

=== Page 2 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 2 of 4
may not be used to advance new facts, issues or arguments not
previously presented to the Court, nor may it be used as a vehicle
for relitigating issues already decided by the Court." Bennett V.
Watson Wyatt & Co., 156 F. Supp. 2d 270, 271 (S.D.N.Y. 2001).
Here, Ms. Maxwell's request for reconsideration hinges on her
assertion that new developments, i.e., her indictment and arrest,
provide compelling reasons for keeping the deposition transcripts
sealed. (See dkt. no. 1078 at 5.) But, despite Ms. Maxwell's
contention that she could not address the effect of those events
in her objections because they occurred after the close of
briefing, (id.), 1 this is plowed ground. Indeed, in her original
objection to unsealing, Ms. Maxwell argued that the specter of
ongoing criminal investigations into unknown individuals
associated with Jeffrey Epstein--a group that, of course, includes
Ms. Maxwell--loomed large over the Court-ordered unsealing
1 The Court notes as a practical matter that Ms. Maxwell was
arrested on July 2, 2020-that is, three weeks prior to the Court's
July 23 decision to unseal the materials at issue. To the extent
that they relate to the to the Court's balancing of interests in
the unsealing process, the issues that Ms. Maxwell raises in her
request were surely plain the day that Ms. Maxwell was apprehended.
Ms. Maxwell, however, did not seek to supplement her objections to
unsealing despite ample time to do SO. In fact, the Court notified
the parties on July 21, 2020, that it would announce the unsealing
decision with respect to Ms. Maxwell's deposition, together with
other documents, on July 23. (See dkt. no. 1076.) Even then, Ms.
Maxwell made no request for delay or to supplement her papers.
Ms. Maxwell did not raise her "vastly different position,"
(Transcript of July 23 Ruling at 16:2-3), until moments after the
Court had made its decision to unseal the relevant documents.
2
EFTA00018295

=== Page 3 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 3 of 4
process. (See dkt. no. 1057 at 5.) This argument, specifically
Ms. Maxwell's concern that unsealing would "inappropriately
influence potential witnesses or alleged victims," (id.), and her
reference to "publicly reported statements by Plaintiff,
Plaintiff's counsel, the United States Attorney for the Southern
District of New York, and the Attorney General for the U.S. Virgin
Islands" about those investigations, (id.), carried with it the
clear implication that Ms. Maxwell could find herself subject to
investigation and, eventually, indictment. The Court understood
that implication as applying to Ms. Maxwell and thus has already
considered any role that criminal charges against Ms. Maxwell might
play in rebutting the presumption of public access to the sealed
materials. Ms. Maxwell's request for reconsideration of the
Court's July 23 ruling is accordingly denied.
Given the Court's denial of Ms. Maxwell's request for
reconsideration, the Court will stay the unsealing of Ms. Maxwell's
and Doe 1's deposition transcripts and any sealed or redacted order
or paper that quotes from or discloses information from those
deposition transcripts for two business days, i.e., through
Friday, July 31, 2020, so that Ms. Maxwell may seek relief from
the Court of Appeals. Any sealed materials that do not quote from
or disclose information from those deposition transcripts shall be
unsealed on July 30, 2020, in the manner described by the Court's
Order dated July 28, 2020. (See dkt. no. 1077.) Ms. Maxwell's and
3
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=== Page 4 ===
Case 1:15-cv-07433-LAP Document 1079 Filed 07/29/20 Page 4 of 4
Doe 1's deposition transcripts and any sealed materials that quote
or disclose information from them shall be unsealed in the manner
prescribed by the July 28 Order on Monday, August 3, 2020, subject
to any further stay ordered by the Court of Appeals.
so ORDERED.
Dated:
New York, New York
July 29, 2020
LORETTA A. PRESKA
Senior United States District Judge
4
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=== Page 1 ===
From:
To: testimony
Subject: Accepted: 227815.002 USA V GHISLAINE MAXWELL 20 CR 330 (AJN)
Date: Tue, 23 Nov 2021 18:35:28 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Expert Witness
Date: Wed, 28 Oct 2020 18:24:19 +0000
Importance: Normal
Good afternoon
This case is scheduled for trial on July 12, 2021? If so, would you be able to give me a brief summary
for r.Cooper to review? Once she has a chance to review it, I will be happy to schedule a conference
call between you.
Thanks for your kind consideration.
Warm regards,
Legal & Conference Coordinator
Developmental & Forensic Pediatrics, P.A.
cell:
Original Message
From:
Sent: Wednesday, October 28, 2020 1:24pm
To:
Cc:
Subject: Expert Witness
Good afternoon,
My colleagues,
and
and I are the prosecutors in the case of United
States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2020 in the Southern District
of New York. We are reaching out because we would be interested in speaking with Dr. Cooper about
potentially testifying at trial. Would it be possible to schedule a call with Dr. Cooper to discuss?
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: disclosure
Date: Fri, 12 Jul 2019 15:10:34 +0000
Importance: Normal
Attachments: Scan_6.pdf
This is Epstein's financial disclosure.
Judge Berman denied our pending request for some extra time with a docket note that reads - seriously - "Hard to
imagine it would take the Govt extra time to review submission."
From:
Sent: Friday, July 12, 2019 11:06 AM
To:
Subject: disclosure
Try not to strain your eyes reading all the pages
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: RE: Epstein SSN
Date: Thu, 08 Aug 2019 21:55:57 +0000
From:
Sent: Thursday, August 8, 2019 5:28 PM
To: Roos, Nicolas (USANYS)
Subject: RE: Epstein SSN
From:
Sent: Thursday, August 08, 2019 17:26
To:
Subject: Epstein SSN
Can you send it to me?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
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=== Page 1 ===
From:
To:
(USANYS)"
Subject: RE: Doud trial
Date: Fri, 18 Dec 2020 02:34:01 +0000
Fine too.
From:
(USANYS)
Sent: Thursday, December 17, 2020 2:49 PM
To:
Subject: RE: Doud trial
Yea that probably works. Or else sometime in the fall when covid is totally gone since Doud is old.
From:
Sent: Thursday, December 17, 2020 2:31 PM
To:
(USANYS)
Subject: RE: Doud trial
So maybe we aim for a mid-July date for Doud, if defense can do it? And assuming you can still do it.
From:
(USANYS)
Sent: Thursday, December 17, 2020 2:19 PM
To:
Subject: RE: Doud trial
Here's my chaotic summer schedule:
- 5/24: U.S. V. Steve Bannon et al (3-4 weeks probably)
- 6/21: U.S. V. Noel (MCC Epstein guards) (1 week)
- 8/16: U.S. V. Adams (MCC guard bribery) (1 week)
- U.S. V. Lev Parnas et al (2-3 weeks) = was scheduled for March but judge moving it to some times in August - October
2021. l'll know in the next week or two what the date is.
I'm not thinking I'll be able to do all of these. Doud would be top 3 trial for me but probably not #1.
From:
Sent: Thursday, December 17, 2020 1:40 PM
To:
(USANYS)
Subject: Doud trial
Hi - Remind me of your schedule this summer for trial. When are you first available?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
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=== Page 1 ===
From: "Miller, Michael"
To:
)"
Cc: "Martin G. Weinberg"
"Weingarten, Reid"
Subject: Re: US V Epstein
Date: Sun, 11 Aug 2019 03:15:25 +0000
The pathologist we have lined up for tomorrow is Michael Baden. We are confirmed for 9 am unless
traffic delays his arrival. Many thanks for reconfirming the start time. Mike
Sent from my iPhone
On Aug 10, 2019, at 11:04 PM,
)
wrote:
Mike,
I just tried calling, but I realize it's very late - moments ago I spoke with an individual at the Office of the
Chief Medical Examiner, Dr. Jason Graham. He said his office was in touch with the family today - I believe
Mark - and he had the understanding a pathologist was lined up for tomorrow, but based in the newer
understanding that you conveyed, that more time is needed, they are prepared to delay tomorrow the autopsy
(which was otherwise planned for tomorrow morning). Hey conveyed that permitting a pathologist is a
courtesy they extend in this type of situation, and that an additional day or two will not have an effect in their
ability to evaluate the cause and manner of death.
Accordingly, he asked that you please contact him tonight or tomorrow morning to arrange logistics of the
pathologist who ultimately will join; Dr. Graham's e-mail is:
As of tonight, my understanding is that he has instructed his staff not to proceed tomorrow morning, pending
being in touch with you for further coordination.
Please let me know if there are any issues being in contact with him, and also feel free to contact me generally
if that would be helpful.
thank you,
On Aug 10, 2019, at 19:35, Miller, Michael
wrote:
Thanks for being available today and for getting the wheels turning for an investigation into how he died.
On a related note, we are hearing that Jeffrey's autopsy may occur tomorrow morning. We would like to
have a pathologist present for his autopsy and cannot line up someone on such short notice. Is there any
way to push the autopsy off until Tuesday to give us time to do that?
Mike
EFTA00019953

=== Page 2 ===
From:
Sent: Saturday, August 10, 2019 7:31 PM
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: RE: US V Epstein
Mike, Marty, Reid,
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a
brief note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will
continue to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the
investigations of these events will be thorough and swift.
respectfully,
From:
Sent: Saturday, August 10, 2019 14:14
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: RE: US V Epstein
Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well
(in addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations
ongoing, including as initiated by the Attorney General himself. Separately, we have not received additional
information on topics such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc.,
but we will continue to be in touch immediately if that changes.
thank you,
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike
moments ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago.
It represents all the information we have from BOP so far, but of course if we are successful in our continuing
efforts to get additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
EFTA00019954

=== Page 3 ===
thank you,
EFTA00019955


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
Subject: Ghislaine Maxwell (02879-509)
Date: Sun, 01 Nov 2020 17:41:16 +0000
Good afternoon-
I write to request immediate assistance for Ghislaine Maxwell.
There are many conditions and restrictions placed upon her at the MDC
that are of great complaint, but of immediate concern are conditions within
Ms. Maxwell's isolation cell.
The combination of cold, moisture, and sewage stench have made confinement
in her cell unhealthy, unbearable, and utterly unreasonable.
Her request for an extra blanket has been denied.
Her request for use of her day mug for water has been denied.
(She's been told to cup her hands to drink water from the faucet.)
Her request to keep a snack in her cell has been denied.
The moisture accumulating in her cell risks her health and the security
of her legal work.
You have known me and my reputation among your colleagues and the court.
Trust me when I way that in my 35 years of federal criminal practice, having represented
individuals charged and convicted of terrorism and capital murder, housed in
MCC's 10South and FCI Florence-ADMAX (facilities I have visited), I have never witnessed
such inappropriate and outlandish treatment of a non-violent pretrial detainee held on risk of flight.
The mistreatment of Ghislaine Maxwell reflects negatively on your Office, the Court,
and the BOP. The Government as a whole can and needs to do better.
For today, we seek the bare minimum - a change of cell to a location that is safe
from the cold, moisture, and stench, and an extra blanket to keep her warm.
The rest will be left for another day.
Please assist.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
EFTA00019140

=== Page 2 ===
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
EFTA00019141


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=== Page 1 ===
Google LLC
Mountain View, California 94043
Google
www.google.com
09/01/20
Federal Bureau of Investigation
New York, NY 10278
Re: Grand Jury Subpoena dated August 26, 2020 (Google Ref. No. 3971083)
2018R01618; 20 MAG 9134
Dear
:
Pursuant to the Grand Jury Subpoena issued in the above-referenced matter, we have
conducted a diligent search for documents and information accessible on Google's systems that
are responsive to your request. Our response is made in accordance with state and federal law,
including the Electronic Communications Privacy Act. See 18 U.S.C. § 2701 et seq.
Accompanying this letter is responsive information to the extent reasonably accessible
from our system associated with the Google account(s)
that used
as Google account sign-in(s)
as specified in the Grand Jury
Subpoena. We have also included a signed Certificate of Authenticity which includes a list of
hash values that correspond to each file contained in the production. Google may not retain a
copy of this production but does endeavor to keep a list of the files and their respective hash
values. To the extent any document provided herein contains information exceeding the scope of
your request, protected from disclosure or otherwise not subject to production, if at all, we have
redacted such information or removed such data fields.
Google objects and has not produced records associated with Google accounts for which
you have not expressly provided an account identifier or which derive from records or other
information of the subject account(s) that you seek to have Google search. Because this exceeds
the scope of 18 U.S.C. $ 2703(c)(2), Google requires a court order pursuant to 18 U.S.C. $
2703(d) based on specific and articulable facts showing that the accounts linked by secondary
email address are relevant and material to your investigation for the duration of the time period
requested. Moreover, bulk requests for information about a large number of unidentified or
unspecified Google users is both burdensome to Google and may implicate the First Amendment
or other rights of Google users. See In re Grand Jury Subpoena to Amazon.com Dated August 7,
2006, 246 F.R.D. 570, 573 (D. Wis. 2007) (applying First Amendment analysis to grand jury
subpoena for bulk Amazon customer data). To the extent you seek information about additional
Google accounts, Google can comply with legal process that expressly contains an account
identifier for each of those accounts that you determine are relevant to your investigation.
The identifier(s),
you provided is not unique and cannot be
associated to a specific subscriber's account. Therefore, we do not have documents responsive to
your request for this identifier.
EFTA00019636

=== Page 2 ===
Google LLC
Mountain View, California 94043
Google
www.google.com
After a diligent search and reasonable inquiry, we have found no records for any Google
account-holder(s) identified as
Therefore, we do not have documents responsive
to your request.
Please note that a subpoena is not sufficient process to compel production of the account
status associated with the specified account. The scope of information available pursuant to a
subpoena is limited to the items specified in section 2703(c)(2) of the Electronic Communications
Privacy Act ("ECPA"). 18 U.S.C. §2701 et seq. A court order issued under section 2703(d) or a
search warrant is required to compel production of other "record[s] or other information" such as
the account status of a specified account. 18 U.S.C.2703(c)(1).
Please note that Google Pay service data is under the control of Google Payment
Corporation. Any request for such data must be specifically addressed to Google Payment
Corporation and can be served through the email address
For a Google Custodian of Records, we will require a subpoena and confirmation from
you of the time and date of the appearance, the scope of testimony, any Google Reference
Number(s) associated with the case, and the travel for the appearance at least one week in
advance in order to identify, make the appropriate plans for, and prepare a custodian for trial.
Finally, in accordance with Section 2706 of the Electronic Communications Privacy Act,
Google may request reimbursement for reasonable costs incurred in processing your request.
Regards,
Albert Sanchez
Google Legal Investigations Support
EFTA00019637

=== Page 3 ===
Google LLC
Mountain View, California 94043
Google
www.google.com
CERTIFICATE OF AUTHENTICITY
I hereby certify:
1.
I am authorized to submit this affidavit on behalf of Google LLC ("Google"), located in
Mountain View, California. I have personal knowledge of the following facts, except as noted,
and could testify competently thereto if called as a witness.
2.
I am qualified to authenticate the records because I am familiar with how the records
were created, managed, stored and retrieved.
3.
Google provides Internet-based services.
4.
Attached is a true and correct copy of records pertaining to the Google account(s)
that used as Google account sign-in(s)
with
Google Ref. No. 3971083 ("Document"). Accompanying this Certificate of Authenticity as
Attachment A is a list of hash values corresponding to each file produced in response to the Grand
Jury Subpoena.
5.
The Document is a record made and retained by Google. Google servers record this data
automatically at the time, or reasonably soon after, it is entered or transmitted by the user, and this
data is kept in the course of this regularly conducted activity and was made by regularly
conducted activity as a regular practice of Google.
6.
The Document is a true duplicate of original records that were generated by Google's
electronic process or system that produces an accurate result. The accuracy of Google's
electronic process and system is regularly verified by Google.
7.
Pursuant to 28 U.S.C. $ 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge.
/s Albert Sanchez
Date: 09/01/20
(Signature of Records Custodian)
Albert Sanchez
(Name of Records Custodian)
EFTA00019638

=== Page 4 ===
Google LLC
Mountain View, California 94043
Google
www.google.com
Attachment A: Hash Values for Production Files (Google Ref. No. 3971083)
GoogleAccount.SubscriberInfo_001.zip:
MD5-c1bad631b1bdf99736a322fa123bb39a
SHA512-
0503ebc3065955adb3a33d9e72e1a9a8a669f394389e42d805ebccde97d07d525084fee85d83f3320
73fce9f14540eb1217bde0edfc6d95335b972a728c9938d
EFTA00019639


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=== Page 1 ===
From:
To:
Subject: RE: status memo draft
Date: Wed, 06 Mar 2019 17:42:18 +0000
Importance: Normal
sorry,
From:
Sent: Wednesday, March 06, 2019 12:42
To:
Subject: RE: status memo draft
?
From:
Sent: Wednesday, March 6, 2019 12:39 PM
To:
Subject: RE: status memo draft
302:
During one of the visits Epstein asked her
and she told him no.
302:
Epstein wanted
to
Epstein used his hand to direct
From:
Sent: Wednesday, March 06, 2019 10:17
To:
Subject: RE: status memo draft
Redline attached let me know if you want to discuss. Thanks!
From:
Sent: Tuesday, March 5, 2019 9:22 PM
To:
Subject: status memo draft
Thoughts? It's a little on the long side (chiefs said ~3 pages was fine) just due to the legal analysis, but they can always cut
that down. Anyway I've never done one of these in particular before so very happy for suggestions. Thanks!
EFTA00019479


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Referral of MLAT Request from France
(
Date: Wed, 30 Dec 2020 15:06:08 +0000
Attachments: 2020002015-Depi_En.pdf; 2020002015-Depi_Fr.pdf;
Referral_Letter_(SDNY)_(December_2020).pdf
FYI
From:
Sent: Wednesday, December 30, 2020 9:32 AM
To:
Subject: FW: Referral of MLAT Request from France
From:
Sent: Wednesday, December 30, 2020 5:58 AM
To:
Cc:
Subject: Referral of MLAT Request from France
Dear
I hope you are both doing well, and have been enjoying the end of year festivities.
I am referring for your attention an MLAT request from the French in relation to their investigation of
(who was recently arrested and placed under examination here in Paris). Since I have been in touch anyway with
and
about the Maxwell bail proceedings, I took the opportunity to mention that this might be
coming their way.
Thanks in advance, and happy new year!
DOJ Attaché/Magistrat de liaison américain
U.S. Embassy, Paris
Ofc.
Mob
EFTA00018658


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=== Page 1 ===
From:
To:
Subject: RE: grand jury
Date: Tue, 23 Jun 2020 14:34:12 +0000
Attachments: GJ - _Flights_and_Excerpts.pptx
Hey - - here's the PowerPoint with everything from your two emails. For the excerpts, I was a bit unsure because there
were a lot of objections which I chose to leave in out of caution. Let me know if I should be going back and making
changes.
From:
Sent: Monday, June 22, 2020 10:32 PM
To:
Subject: RE: grand jury
Apologies for piling on, but if you could please also make slides that have the following excerpts of the attached
deposition testimony, that would be a huge help as well:
The cover page of both days of testimony (so the caption and date shows)
The following five excerpts (I think you should be able to just control-F to locate):
1)
Q.
Did Jeffrey Epstein have a scheme to recruit underage girls
for sexual massages? If you know.
A.
I don't know what you're talking about.
2)
Q.
List all the people under the age of 18 that you interacted
with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with, other than
obviously
who was 17 at this point.
3)
Q: Were you aware of the presence of sex toys or devices used in
sexual activities in Mr. Epstein's Palm Beach house?
A: No, not that I recall.
Q.
Do you know whether Mr. Epstein possessed sex toys or
devices used in sexual activities?
EFTA00020228

=== Page 2 ===
A.
No.
4)
Q.
Other than yourself and the blond and brunette that you have
identified as having been involved in three-way sexual
activities, with whom did Mr. Epstein have sexual
activities?
A.
I wasn't aware that he was having sexual activities with
anyone when I was with him other than myself.
Q.
I want to be sure that I'm clear. Is it your testimony that
in the 1990s and 2000s, you were not aware that Mr. Epstein
was having sexual activities with anyone other than yourself
and the blond and brunette on those few occasions when they
were involved with you?
A.
That is my testimony, that is correct.
5)
Q.
Is it your testimony that you've never given anybody a
massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a massage, is that your
testimony?
A.
That is my testimony.
Q.
You never gave [Minor Victim-2] a massage is your testimony?
A.
I never gave [Minor Victim-2] a massage.
Thank you! Very much appreciated.
From:
Sent: Monday, June 22, 2020 7:17 PM
To:
Subject: RE: grand jury
Fantastic, thanks! Attached is a sample slide for a model. All the slides will be this same format-the document is an
excerpt from flight records. The records are attached - could you please make slides excerpting the records (and flagging
the date) for the following flight dates:
November 11, 1996.
May 9, 1997
May 3, 1998
EFTA00020229

=== Page 3 ===
August 18, 1994
August 20, 1994
January 3, 1995
February 12, 1995
No need for any introductory material - l'll just drag these slides into my presentation once you prep them. Thanks a ton!
This is a big help.
From:
Sent: Monday, June 22, 2020 7:10 PM
To:
Subject: Re: grand jury
Hi
l'll be sure to have time tomorrow. Just let me know what you need and I can handle it.
Will
On Jun 22, 2020, at 6:50 PM,
wrote:
Hey
I'm working on a grand jury presentation on a compressed timeframe, and was hoping you might be able to help put
together a few slides. I'm handling the rest of the slides, but if you could possibly make about seven slides to drop in,
that would be a big help - I need to add a few that will all be the same format. Any chance you have time tomorrow?
Thanks!
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00020230


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=== Page 1 ===
Event: Accepted: Epstein pre-meet
Start Date: 2019-04-08 13:30:00 +0000
End Date: 2019-04-08 14:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-04-07 13:42:07 +0000
Date Modified: 2019-04-07 13:42:07 +0000
Priority: 5
DTSTAMP: 2019-04-06 18:28:16 +0000
Attendee:
EFTA00019553


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: proposed schedule.
Date: Tue, 24 Sep 2019 13:26:57 +0000
I think so, but we are going to chat today or tomorrow and we will know more after that.
It will get done. No reason not to.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Sep 24, 2019, at 9:09 AM,
wrote:
Can you commit to getting us a proposed schedule by October 4 (the end of next week), and we can meet later the
following week?
Assistant United States Attorney
Subject: Re: proposed schedule.
Good morning,
We are still working internally on a proposed schedule. Can we circle back to you on a week or two? We
should still have plenty of time to meet and hopefully agree on dates before our next status conference.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
EFTA00019695

=== Page 2 ===
Barket Epstein.com
On Sep 21, 2019, at 9:33 AM,
wrote:
We are free Thursday afternoon except from 2:45 - 4.
Assistant U.S. Attorney
On Sep 21, 2019, at 07:22,
wrote:
Any day next week works for me. Also in my role as Learned Counsel, and in full compliance with the ABA
Guidelines, I will be submitting a proposed schedule for penalty phase pleadings over the weekend.
Thanks
Tonyricco
Original Message
Sent: Fri, Sep 20, 2019 9:15 pm
Subject: Re: proposed schedule.
We are free next Friday afternoon if that works for you all.
Assistant U.S. Attorney
On Sep 20, 2019, at 12:16, Bruce Barket
wrote:
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you can meet
to discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have ours finalized no
later than Tuesday.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road Ste. 700
Garden City. NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If
it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in
error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you
have received this communication in error, please notify us immediately by telephone or email and immediately delete
this message and all its attachments
EFTA00019696


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: State Attorney's Office - New Document Available - Case No 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:44:42 +0000
Thank you. The paralegal on the case, who is cc'd here, will download the documents.
On Sep 14, 2020, at 3:41 PM,
wrote:
There is a new file available.
Case Number 2020PR000426AMB
Defendant Name JEFFREY E EPSTEIN
Please click here to download the file.
When setting up initial account, please be sure to check your spam/junk email folder for the notification email.
Sent By
EFTA00019644


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Fri, 26 Mar 2021 22:28:07 +0000
Hi Jeff,
Thanks very much-I appreciate the heads up about scheduling, and that's not a problem, we can definitely work around
your schedule. With respect to notification, we have no objection to Interlochen notifying the students (who are now
adults) about the subpoena. As we discussed, we would otherwise request that you refrain from disclosing to third
parties.
Thanks, and hope you have a good weekend-
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
EFTA00019582

=== Page 2 ===
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
EFTA00019583

=== Page 3 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
EFTA00019584

=== Page 4 ===
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
EFTA00019585

=== Page 5 ===
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
EFTA00019586

=== Page 6 ===
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00019587

=== Page 7 ===
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks verv much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
EFTA00019588

=== Page 8 ===
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019589

=== Page 9 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From: "
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best
Assistant United States Attorney
Southern District of New York
EFTA00019590

=== Page 10 ===
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From: "
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
EFTA00019591

=== Page 11 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019592


c1: EFTA00019288
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019288.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
Date: Fri, 18 Dec 2020 04:43:13 +0000
I'm struggling to remember what happened after we asked for this. I think
was running point on that.
Sent from my iPhone
On Dec 17, 2020, at 9:57 PM,
wrote:
do you remember what the status is of the estate complying with our subpoena for these kinds of
materials?
Begin forwarded message:
From:
Date: December 17, 2020 at 9:21:12 PM EST
To:
Subject: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
FWIW
https://okmagazine.com/exclusives/jeffrey-epstein-video-recordings-darren-indyke/
Sent from my iPhone
EFTA00019288


c1: EFTA00020254
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020254.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
king, linsel
Tuesday, October 15, 2019 9:34:AM
To:
Be Photos
Thank you
Get lecks
Prom
1a
Property of
- Not For Media Use
00011688
CONFIDENTIAL
SDNY_GM_02753423
EFTA00020254

=== Page 2 ===
Property of
- Not For Media Use
00011689
CONFIDENTIAL
SDNY_GM_02753424
EFTA00020255

=== Page 3 ===
main
Property of
- Not For Media Use
00011690
CONFIDENTIAL
SDNY_GM_02753425
EFTA00020256

=== Page 4 ===
Property of
- Not For Media Use
00011691
CONFIDENTIAL
SDNY_GM_02753426
EFTA00020257

=== Page 5 ===
Property of
- Not For Media Use
00011692
CONFIDENTIAL
SDNY_GM_02753427
EFTA00020258

=== Page 6 ===
ROBERT
DOISNEAU
Property of
- Not For Media Use
00011693
CONFIDENTIAL
SDNY_GM_02753428
EFTA00020259

=== Page 7 ===
Sent from from my my iPhose
Property of
- Not For Media Use
00011694
CONFIDENTIAL
SDNY_GM_02753429
EFTA00020260


c1: EFTA00018078
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018078.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
)"
)"
Subject: Re: Epstein Sharing Order Part II
Date: Fri, 31 Jan 2020 03:33:54 +0000
Thanks, let's chat in the morning. I think we should include everything we got.
Sent from my iPhone
On Jan 30, 2020, at 7:21 PM,
)
wrote:
I apologize for the delay on this - I've added the relevant language about revocations to both the application and the
order, and corrected a stray typo, so that stuff is good to go. But two quick things to note, not to belabor this, but - it
doesn't look like there's any reference to the Trust Two documents - that may be because they're not referenced in any
will? At a glance I don't see Trust Two in any of the wills, but I'd want to go back and look more thoroughly unless
somebody already made the decision on that basis. And second, it references a 2019 Trust but I don't see any
documents on that? I have to run out tonight but can certainly circle up with
and/or
tomorrow on any of this,
or just ignore it if I've misread.
thanks,
From:
(USANYS)
Sent: Thursday, January 30, 2020 12:05
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
is
(USANYS)
EFTA00018078

=== Page 2 ===
Cc:
is
)
>
Subject: RE: Epstein Sharing Order Part Il
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
From:
)
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
>;
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part II
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have
now received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
<2019.12.19 Epstein 6(e) App Order.ebd.ajr.docx (002) (002).docx>
EFTA00018079


c1: EFTA00019760
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019760.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Automatic reply: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 15:26:30 +0000
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses may be
delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00019760


c1: EFTA00018541
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018541.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: SDNY NEWS CLIPS, THURSDAY, JANUARY 4, 2021
Date: Thu, 04 Feb 2021 23:24:57 +0000
Inline-Images: image001. png
OF
SDNY PRESS CLIPPINGS
JUSTITIA
Newsday Five current or former LIRR workers indicted on fraud, conspiracy charges The indictment. brought forth by the U.S. Attorney's Office for the Southern District of New York. charges that four LIRR employees
or retirees 34 mins ago
Law com SDNY Trials Delayed Through Feb. 12, McMahon Says I New The chief judge of the U.S. District Court for the Southern District of New York has extended the court's suspension of jury trials through Feb.
1 month ago
Fox Business Hedge fund founder pleads guilty in Neiman Marcus-tied case A hedge fund founder pleaded guilty Wednesday to a criminal charge alleging he defrauded Neiman Marcus creditors by pressuring an
15 hours ago
Daily Mail Trump tax returns: Biden's team given time to decide how to proceed hush money payments that the president's former lawyer and fixer Michael Cohen paid before the 2016 election to two women a
pornographic film star and a 6 hours ago
PoliticusUSA Trump's Banker Was Ousted at Deutsche Bank After She Failed to Disclose Business She Did with a Client clued investigators in on "Individual 1" and hush money payments made to adult film actress
Stormy Daniels to buy her silence ahead of the 2016 election. 7 hours ago
Bloomberg Could Covid Isolation Explain Both Capitol Riots and GameStop? During the era of civil disobedience. Americans marched for civil rights or to protest the Vietnam War. Sometimes they broke the law
deliberately, but there was a 7 hours ago
NYPD, Civilian Complaint Review Board Agree On Process To Discipline Officers - CBS New York (cbslocal.com)
"Unprecedented" NYC police discipline guidelines could serve as model throughout US ABC News (go.com)
New York Under Fire for Vaccinating Prison Staff, Not Inmates - Courthouse News Service
The Hill Epstein victims compensation fund suspended due to liquidity issues I TheHill British socialite Ghislaine Maxwell, who has been accused of recruiting young girls as his victims and participating in their
sexual abuse, was arrested in New 3 hours ago
David Jones's Appointment (2nd Circuit)
Bitcoin Agent Avoids Prison For Lying To Get 25M Payment Law360
Crain's New York Business Cuomo dealt another blow on New York nursing-home death The ruling was the latest blow to Gov. Andrew Cuomo, who has tried to deflect a barrage of criticism that state policies
under his leadership led to an increase of 10 hours ago
United States Department of Justice
U.S. Attorney's Office |Southern District of New York
EFTA00018541


c1: EFTA00018933
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018933.pdf
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c0:
=== Page 1 ===

=== Page 2 ===

=== Page 3 ===

=== Page 4 ===

=== Page 5 ===

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c1: EFTA00017841
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017841.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: Maxwell Letter
Date: Thu, 20 Aug 2020 19:13:53 +0000
Attachments: 2020-08-20_GM_letter_to_Judge_Nathan_re_unsealing_materials.rd.docx
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00017841


c1: EFTA00017890
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017890.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
(USANYS) [Contractor]"
Cc:
)"
Subject: [EXTERNAL] Subpoena to Lockheed Martin - United States V. Maxwell
Date: Tue, 23 Nov 2021 18:50:56 +0000
Attachments: Maxwell_Subpoena_-_LM_Production_It.pdf
Hi
I'm having issues accessing the folder. I've cc'd our eDiscovery expert,
,
as I'm hoping if I put the two of you in
touch you can iron it out.
The files being produced are outlined in the attached correspondence and will be Bates labeled.
Regards,
From:
(USANYS) [Contractor]
Sent: Saturday, November 20, 2021 12:15 PM
To:
(US)
Cc:
Subject: EXTERNAL: RE: Subpoena to Lockheed Martin
Hi
Morning, I've created a USAFx folder between us for sharing these materials, linked below:
If you have any trouble accessing your USAFx account, please let me know and I can reset your account.
Best,
Paralegal Specialist
U.S. Attorney's Office, SDNY
From:
Sent: Friday, November 19, 2021 8:01 PM
To:
EFTA00017890

=== Page 2 ===
Cc:
(USANYS) [Contractor]
Subject: RE: Subpoena to Lockheed Martin
Hi
I hope all's well.
has left our office, so I'm copying
here, who can help you or a colleague get set up with
USAFX.
or a colleague has a production for us and needs a USAFX account.
Thanks!
EFTA00017891


c1: EFTA00019477
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019477.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: www.nbcnews.com: Jeffrey Epstein's deal with federal prosecutors wasn't normal. The men
who arranged it need to face the music.
Date: Fri, 01 Mar 2019 12:14:30 +0000
Importance: Normal
Jeffrey Epstein's deal with federal prosecutors wasn't normal. The men who arranged it need to face the
music.
www.nbcnews.com
Read the full story
EFTA00019477


c1: EFTA00019805
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019805.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
PP37
Page 1 of 1
*
INMATE HISTORY
08-10-2019
NYMHM 531.01 *
*
PAGE 001 OF 001 *
ADM-REL
10:40:24
REG NO..: 76318-054 NAME....: EPSTEIN, JEFFREY EDWARD
CATEGORY:
ARS
FUNCTION:
DIS
FORMAT:
FCL
ASSIGNMENT DESCRIPTION
START DATE/TIME STOP DATE/TIME
NYM
L HOSP USM ESC TRP TO LOC HOSP W/RETN-USM
08-10-2019 0747 CURRENT
NYM A-PRE
PRE-SENT ADMIT, ADULT
07-08-2019 1749 08-10-2019 0747
NYM COURT
COURT APPEARANCE W/SCHED RETRN 07-08-2019 0920 07-08-2019 1749
NYM A-PRE
PRE-SENT ADMIT, ADULT
07-06-2019 2124 07-08-2019 0920
G0005
TRANSACTION SUCCESSFULLY COMPLETED - CONTINUE PROCESSING IF DESIRED
https://bop.tcp.doj.gov.9049/SENTRY/J1P160do
8/10/2019
EFTA00019805

=== Page 2 ===
Page 1 of 1
PP37
*
INMATE HISTORY
08-10-2019
NYMHM 531.01 *
*
PAGE 001 OF 001 *
QUARTERS
10:41:01
REG NO..: 76318-054 NAME....: EPSTEIN, JEFFREY EDWARD
CATEGORY:
QTR
FUNCTION: DIS
FORMAT:
FCL
ASSIGNMENT DESCRIPTION
START DATE/TIME STOP DATE/TIME
NYM
Z04-206LAD HOUSE Z/RANGE 04/BED 206L AD
07-29-2019 1221 08-10- 2019 0747
H01-001L HOUSE H/RANGE 01/BED 001L
07-23-2019 0324 07-29-2019 1221
NYM
Z05-124LAD HOUSE Z/RANGE 05/BED 124L AD
07-10-2019 1526 07-23- 2019 0324
NYM
NYM
H01-001L
HOUSE H/RANGE 01/BED 001L
07-08-2019 1803 07-10- 2019 1526
NYM
z02-201LAD HOUSE Z/RANGE 02/BED 201L AD
07-08-2019 1749 07-08-2019 1803
NYM
z02-201LAD HOUSE Z/RANGE 02/BED 201L AD
07-07-2019 1920 07-08-2019 0920
NYM
E06-547U
HOUSE E/RANGE 06/BED 547U
07-06-2019 2136 07-07- 2019 1920
NYM
R01-001L
HOUSE R/RANGE 01/BED 001L
07-06-2019 2124 07-06-2019 2136
G0005
TRANSACTION SUCCESSFULLY COMPLETED - CONTINUE PROCESSING IF DESIRED
https://bop.cp.o.gov:9049/SENTRY/J1P160.do.
8/10/2019
EFTA00019806

=== Page 3 ===
Page 1 of 1
PP10
NYMHM 535.07 *
CIM CLEARANCE AND SEPARATEE DATA
*
08-10-2019
*
10:31:37
PAGE 001 OF 001 *
REGISTER NO: 76318-054 NAME: EPSTEIN, JEFFREY EDWARD
REGISTER
FIRST
ARS ARS
ARS
ARS QTR
NUMBER LAST NAME
NAME
FCL ASSIGN
DATE
TIME ASSIGN
76318-054 EPSTEIN
JEFFREY NYM L HOSP USM 08-10-2019 0747
*****
FOI EXEMPT
P0011
THIS INMATE HAS NO CMC ASSIGNMENTS
https://boptcp.doj.gov9049/SENTRY/J1PPG20.do.
8/10/2019
EFTA00019807

=== Page 4 ===
NYMHM 535.03 *
INMATE PROFILE
08-10-2019
PAGE 001 OF 001
09:28:51
76318-054
REG
REGNO: 76318-054
FUNCTION: PRT DOB/AGE.:
/ 66
NAME.: EPSTEIN, JEFFREY EDWARD
R/S/ETH.: W/M/O
WALSH:
YES
RSP..: NYM-NEW YORK MCC
MILEAGE.: 5 MILES
PHONE:
FAX:
ARS ASSIGNMENT..: ESC TRP TO LOC HOSP W/RETN-USM FBI NO..:
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INS NO..:
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=== Page 5 ===
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8/10/2019
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=== Page 6 ===
PD15
Page 1 of 1
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*
08-10-2019
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*
09:30:45
PAGE 001 OF 001 *
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G5463
NO ENTRIES EXIST IN CHRONOLOGICAL LOG FOR TIME PERIOD REQUESTED
https://bop.tcp.oj.gov:9049/SENTRY/J1PPD50.do
8/10/2019
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=== Page 7 ===
PD15
Page 1 of 1
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*
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09:30:56
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8/10/2019
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=== Page 8 ===
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s0057
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8/10/2019
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=== Page 9 ===
NYMHM 533*01 *
DEPARTMENT OF JUSTICE
08-10-2019
PAGE 001
*
ASSIGNMENT HISTORY REPORT
*
09:31:50
REG NO: 76318-054 NAME: EPSTEIN
JEFFREY
EDWARD
ADM-REL
RESPONSIBILITY OF:
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STOP DATE
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----
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----
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----
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----
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----
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----
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07-06-2019 2124 CURRENT
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----
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NYMHM 533*01 *
DEPARTMENT OF JUSTICE
08-10-2019
PAGE 002
*
ASSIGNMENT HISTORY REPORT
*
09:31:50
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RESPONSIBILITY OF:
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START DATE/TIME STOP DATE
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HOSPITAL
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ATTORNEY VISIT
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NEW YORK MCC
ATTORNEY VISIT
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NEW YORK MCC
ATTORNEY VISIT
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NEW YORK MCC
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ATTORNEY VISIT
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NEW YORK MCC
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NEW YORK MCC
ATTORNEY VISIT
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NEW YORK MCC
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ATTORNEY VISIT
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NEW YORK MCC
ATTORNEY VISIT
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NEW YORK MCC
ATTORNEY VISIT
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NEW YORK MCC
ATTORNEY VISIT
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1920
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NEW YORK MCC
HOUSE R/RANGE 01/BED 001L
6702-90-10 5777
RELIGION
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STAR. DATE/TIME STOP DATE
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RELIGION UNKNOWN
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SECOND RSP
RESPONSIBILITY OF:
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START DATE/TIME STOP DATE
SECUR THRT
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START DATE/TIME STOP DATE
NEW YORK MCC
HISTORY OF COMMITTING RAPE
07-10-2019 1455 CURRENT
UNIT
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START DATE/TIME STOP DATE
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UNT MGR.
EXT
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UNIT MANAGER
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G0000
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NYMHM 533*01 *
DEPARTMENT OF JUSTICE
:
08-10-2019
PAGE 003
*
ASSIGNMENT HISTORY REPORT
09:31:50
QUARTERS
RESPONSIBILITY OF:
-ASSIGNMENTS
START DATE/TIME STOP DATE
NEW YORK MCC
HOUSE E/RANGE 06/BED 547U
07-06-2019 2136 07-07-2019
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NYMHM 533*01 *
DEPARTMENT OF JUSTICE
*
08-10-2019
PAGE 003
*
ASSIGNMENT HISTORY REPORT
*
09:31:50
QUARTERS
RESPONSIBILITY OF:
-ASSIGNMENTS
START DATE/TIME STOP DATE
NEW YORK MCC
HOUSE E/RANGE 06/BED 547U
07-06-2019 2136 07-07-2019
NEW YORK MCC
HOUSE R/RANGE 01/BED 001L
07-06-2019 2124 07-06-2019
RELIGION
RESPONSIBILITY OF:
-
-ASSIGNMENTS
----
START DATE/TIME STOP DATE
NEW YORK MCC
RELIGION UNKNOWN
07-06-2019 2124 CURRENT
SECOND RSP
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----
-ASSIGNMENTS
----
START DATE/TIME STOP DATE
SECUR THRT
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- ---
START DATE/TIME STOP DATE
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UNIT
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----
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EXT
07-22-2019 1806 08-10-2019
NEW YORK MCC
UNIT MANAGER
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----
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----
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G0000
TRANSACTION SUCCESSFULLY COMPLETED
EFTA00019817


c1: EFTA00019528
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019528.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Epstein call
Date: Wed, 09 Jan 2019 16:54:53 +0000
Importance: Normal
Attachments: unnamed
EFTA00019528


c1: EFTA00018709
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018709.pdf
c6: pdf
c7: images
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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
MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S
THIRD MOTION FOR RELEASE ON BAIL
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Christian R. Everdell
COHEN & GRESSER LLP
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Attorneys for Ghislaine Maxwell
EFTA00018709

=== Page 2 ===
INTRODUCTION
Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third
Motion for Release on Bail.
As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no
intention or desire to leave this country. She is an American citizen, has lived in United States
for 30 years, has strong family ties and the support of friends and family residing in this country.
She wants nothing more than to remain in the United States under whatever conditions the Court
deems necessary so that she can effectively prepare for trial and vigorously defend against the
25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to
our knowledge, unprecedented set of bail conditions that would reasonably assure her
appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms.
Maxwell now proposes two additional bail conditions to supplement the extraordinarily
restrictive bail package she has already offered.
First, Ms. Maxwell will renounce her French and British citizenship to eliminate
any opportunity for her to seek refuge in those countries, if the Court so requires.
Second, Ms. Maxwell will have her and her spouse's assets-excluding funds
earmarked for living expenses, for legal fees and other expenses necessary to
defend her against the criminal charges in this case and related civil lawsuits and
for taxes-placed in a new account that will be monitored by a retired federal
District Court judge and former United States Attorney who will function as asset
monitor and will have co-signing authority over the account.
The former condition goes well beyond the extradition waivers that the Court deemed
insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to
seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms.
Maxwell will not be able to avail herself of any protections against extradition that may apply to
2
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=== Page 3 ===
citizens of those countries. The latter condition will restrain Ms. Maxwell's assets so they
cannot be used for flight or harboring her outside of the jurisdiction of this Court. This should
satisfy the Court's concern that the proposed bond was not fully secured and left assets
unrestrained that could be used for such purposes. (See id. at 17-18).
In addition, since the last bail application, Ms. Maxwell has submitted twelve pretrial
motions that raise substantial legal and factual issues that may result in the dismissal of some or
all of the charges against her. Ms. Maxwell referenced some of these motions in her initial bail
application (see Dkt. 18 at 19) but was not in a position to fully articulate them until she had the
chance to review the discovery and research the legal issues in advance of the motion deadline of
January 25. These motions significantly call into question the strength of the government's case
against Ms. Maxwell and the underlying justification for continued detention.
Ms. Maxwell has already been denied a fair chance in the court of public opinion. She
has been maligned by the media, which has perpetuated a false narrative about her that has
poisoned any open-mindedness and impartiality of a potential jury. She has been relentlessly
attacked with vicious slurs, persistent lies, and blatant inaccuracies by spokespeople who have
neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt
to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined -
and welcomes the opportunity - to face her accusers at trial and clear her name. The additional
proposed bail conditions should quell any concerns that she would try to flee. The Court should
therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare
for trial.
3
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=== Page 4 ===
I.
The Proposed Additional Bail Conditions Will Reasonably Assure Ms. Maxwell's
Appearance in Court
As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate
any means or opportunity that she may have to leave the country. The Court should therefore
reconsider its earlier ruling and grant bail under the proposed conditions. See United States V.
Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003) ("[A] release
order may be reconsidered even where the evidence proffered on reconsideration was known to
the movant at the time of the original hearing."); see also United States V. Petrov, No. 15-CR-66-
LTS, 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting "Court's inherent authority for
reconsideration of the Court's previous bail decision").
A.
Renunciation of Foreign Citizenship
To demonstrate her commitment to abide by her conditions of release and to provide
further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is
willing to formally renounce her foreign citizenships in France and the United Kingdom. Should
the Court feel this drastic condition is necessary, the required documents will be submitted to the
appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell's
passports will be surrendered to the government and no further application will be made.
If the Court deems it a necessary condition of release, Ms. Maxwell will formally
commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the
process of being completed. Renunciation of UK citizenship can be accomplished immediately
upon granting of bail. The process of renouncing her French citizenship, while not immediate,
may be expedited.
Citizenship is a precious and priceless asset. Ms. Maxwell's decision to give up
citizenship from the county of her birth and the country of her upbringing demonstrates her
4
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=== Page 5 ===
earnestness to abide by the conditions of her release and underscores that she has no intention to
flee and reflects her deep need to communicate freely with counsel to prepare for her defense.
Her renunciation of foreign citizenship obviates the Court's concerns about the validity of
waivers of extradition. (See Dkt. 106 at 13). Ms. Maxwell will have no ability to contest
extradition from France or the United Kingdom on the basis of citizenship, which removes any
incentive the Court and government believe she may have to seek refuge in those countries.
B.
Restraint and Monitoring of Assets
In denying bail, the Court noted that the bond was not fully secured, and that Ms.
Maxwell and her spouse would still have several million dollars in unrestrained assets that could
be used to facilitate her flight from the country. (See id. at 17-18). To assuage any concerns that
those assets would be available to finance flight to and shelter in a foreign country, Ms. Maxwell
has taken steps to create a monitorship that will place meaningful restraints on the assets that are
not used to secure the bond, while still allowing Ms. Maxwell to pay for her legal defense, for
her spouse to pay for daily living expenditures and for payment of taxes.
1.
New Account
All assets of Ms. Maxwell and her spouse, with the exception of money currently held in
escrow for legal fees and related defense expenses and the funds contained in the bank account in
the name of Ms. Maxwell's spouse ("the Personal Account")1, will be deposited in a newly
created account ("the New Account") to be overseen by an asset monitor appointed pursuant to
order of the Court. The New Account will contain all of Ms. Maxwell's and her spouse's
remaining cash and other liquid assets, including any proceeds that result from the pending sale
1 The Personal Account is identified as Account I on page 9 of the Financial Report annexed to Ms. Maxwell's
Renewed Bail Application. (See Dkt. 97, Exhibit O.)
5
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=== Page 6 ===
of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired.
The asset manager will approve the financial institution at which the New Account is created and
must approve and co-sign any expenditure from the New Account, with the exception of
disbursements for Ms. Maxwell's legal fees in connection with the ongoing criminal and civil
litigation and for payment of taxes, which will not require authorization. No illiquid assets may
be sold, conveyed or transferred without approval of the asset monitor.
2.
Other Assets
The only funds that will not be included in the New Account are (1) the money currently
held in escrow by Ms. Maxwell's attorneys, which will be used exclusively for her defense; and
(2) the roughly $450,000 in the Personal Account which her spouse will use only for living
expenses. The asset monitor shall regularly receive information regarding activity of the Personal
Account, including the account balance, on a weekly basis. The asset monitor must also receive
five-day advance notice of any check, on-line payment, or transfer of funds in any amount
exceeding $5,000, and the reason for such payment. Ms. Maxwell's spouse agrees to be bound
by these restrictions and reporting requirements.
The asset monitor shall report to Pretrial Services any possible non-compliance or
disbursement in violation of the terms and conditions specified above.
3.
Selected Asset Monitor
The Honorable William S. Duffey, Jr., a retired federal District Court judge and the
former United States Attorney for the Northern District of Georgia, has agreed to undertake the
position of asset monitor. (Judge Duffey's bio is attached as Exhibit A.) Judge Duffey has
extensive experience evaluating and monitoring funds held in and disbursed from financial
6
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=== Page 7 ===
accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her
spouse, as described above.
Restraining Ms. Maxwell's assets that are not used to secure the bond and placing them under
the supervision of a former federal District Court judge eliminates any concern that such funds
could be used to violate the terms of release.
II.
Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues
That Could Result in Dismissal of Some or All of the Charges Against Her
In addition to the new conditions proposed above, the numerous substantive pretrial
motions now before the Court amply challenge the purported strength of the government's case.
Ms. Maxwell's pretrial motions raise serious legal issues that could result in dismissal of
charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the
superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay,
and for being based on improperly obtained evidence in violation of Ms. Maxwell's
constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of
the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious
statements. These motions are substantial with a likelihood of success on the merits. These
motions cast substantial doubt on the alleged strength of the government's case and warrant
granting bail on the conditions proposed.
III.
The Court Should Grant Bail
Under the Bail Reform Act of 1984, a defendant must be released on personal
recognizance or unsecured personal bond unless the judicial officer determines "that such release
will not reasonably assure the appearance of the person as required or will endanger the safety of
any other person or the community." 18 U.S.C. $ 3142(b). The enhanced bail package proposed
by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably
7
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=== Page 8 ===
assure her appearance as required. Before preventive detention may be ordered under $ 3142(e),
the Court is obliged to determine both whether the defendant is likely to flee the jurisdiction if
released, and whether any conditions of release will be reasonably certain to guard against this
propensity to flee. The Court expressed concerns and denied bail without indicating what
conditions would be reasonably certain to assure Ms. Maxwell's appearance. Ms. Maxwell is no
danger to the community and not alleged to have been involved in ongoing criminal activity. To
say that there are absolutely no conditions flies in the face of cases where non-United States
citizens with no ties to the district, let alone the country, were released on lesser conditions for
alleged criminality ongoing up to or within hours of the time of arrest, in contrast to 26-year-old
claims alleged against Ms. Maxwell.²
The additional conditions set forth above, which supplement the exceptional bail package
previously proposed, are sufficient to address the hypothetical risk of flight and secure Ms.
Maxwell's presence at trial. The financial magnitude of the proposed bonds, the collateral
pledged to secure the bonds, the stringent requirements of home detention, the renunciation of
foreign citizenship and monitoring of assets contained in a special account from which no funds
can be withdrawn without the approval and signature of a retired federal District Court judge and
former United States Attorney are conditions that amply satisfy the concerns expressed by the
government and the Court. These enditions are unique and unprecedented. They profoundly
2 See Dkt. 97 at 34 (case-comparison chart in the Renewed Motion for Bail); cf. People V. Dominique Strauss-Kahn,
02526/2011(S. N.Y. County). Strauss-Kahn, a French citizen with no ties to the United States, was arrested on a
Paris-bound flight at JFK minutes before takeoff and later charged with several counts of sexual assault, including
felony charges punishable up to 25 years imprisonment, for sexual assault and attempted rape of a Manhattan hotel
housekeeper on the day of his arrest. The accusations were corroborated by semen containing Strauss-Kahn's DNA
on the accuser's uniform. The New York State Supreme Court granted bail in the amount of $1 million cash, 24-
hour home detention electronic monitoring ankle bracelet, and private 24/7 security guards. After surrendering his
French passport and posting an additional $5 million bail bond, Strauss-Kahn was placed under house arrest in a
residence in Manhattan. See https://www.theguardian.com/world/2011/may/20/dominique-strauss-kahn-new-york-
apartment.
8
EFTA00018716

=== Page 9 ===
affirm Ms. Maxwell's earnestness in seeking bail to properly prepare her defense, not to flee.
The Court should grant bail to Ghislaine Maxwell.
CONCLUSION
The proposed additional conditions of release-renunciation of foreign citizenship and
restraint and monitoring of assets by a retired District Court judge-enhance the already
extraordinarily restrictive bail conditions proposed in Ms. Maxwell's Renewed Motion for Bail.
In combination, these conditions satisfy the Bail Reform Act and reasonably assure Ms.
Maxwell's appearance at trial. To deny Ms. Maxwell bail when such extraordinary and
restrictive conditions are available would be a miscarriage of justice.
Dated: February 23, 2021
Respectfully submitted,
Bobbi C. Sternbeim
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Christian R. Everdell
COHEN & GRESSER LLP
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
9
EFTA00018717


c1: EFTA00019198
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019198.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
Date: Tue, 27 Apr 2021 17:59:05 +0000
Congrats!!!
From: cmecf@ca2.uscourts.gov <cmecf@ca2.uscourts.gov>
Sent: Tuesday, April 27, 2021 1:57 PM
To:
Subject: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of
record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents
filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other
users. To avoid later charges, download a copy of each document during this first viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/27/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
MOTION ORDER, denying motion for bail [39] filed by Appellant Ghislaine Maxwell, by PNL, RJL, RJS,
FILED. [3087715][86] [21-58, 21-770]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
EFTA00019198

=== Page 2 ===
The following document(s) are associated with this transaction:
Document Description: Motion Order FILED
Original Filename: 21-58.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/27/2021] [FileNumber=3087715-0]
4f70f4198d95fcdcb8ef868b204742b03e]]
EFTA00019199


c1: EFTA00019767
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019767.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
mcc new YORK
mco new TORK
MCC NEW YORK
SPECIAL HOUSING UNIT
START
SPECIME HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZA
TIER-G
DATE: 08/08/2019
TIME
TIME
TIME
[IME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
FRAME
START
END
START
END
START
END
12:00-12:30 AM
12,3
12"
100-8:30 AM
4:00-4:30 PM
405
406
12:30- 1:00 AM
SALT
12th
30-9:00 AM
4:30-5:00 PM
432
432
1:00-1:30 AM
IN
51)
3:00-9:30 AM
5:00-5:30 PM
505
506
1:30-2:00 AM
153
154
30-10:00 AM
5:30-6:00 PM
536
536
2:00-2:30 AM
219
220
10:00-10:30 AM
6:00-6:30 PM
69
601
2:30-3:00 AM
234
237
0:30-11:00 AM
6:30-7:00 PM
634
634
3:00-3:30 AM
309
3th
1:00-11:30 AM
7:00-7:30 PM
79
701
3:30-4:00 AM
335
336
1:30-12:00 AM
7:30-8:00 PM
734
734
4:00-4:30 AM
423
424
2:00-12:30 PM
8:00-8:30 PM
800
801
4:30-5:00 AM
444
yrs
2:30- 1:00 PM
8:30-9:00 PM
-635
835
5:00-5:30 AM
509
3"
:00-1:30 PM
9:00-9:30 PM
903
903
5:30-6:00 AM
St
541
30-2:00 PM
9:30-10:00 PM
936
935
6:00-6:30 AM
621
622
1:00-2:30 PM
10:00-10:30 PM
1006
1007
6:30-7:00 AM
nen
sdg
2:30-3:00 PM
10:30-11:00 PM
1032
(032
7:00-7:30 AM
701
rd
8:00-3:30 PM
11:00-11:30 PM
1106
1106
7:30-8:00 AM
732
733
30-4:00 PM
11:30-12:00 PM
1134
1134
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
EUTENANT
LIEUTENANT
A all inmates confined focked down status, such as
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019767

=== Page 2 ===
MOO new YORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING UNIT
ZA
TIER-H
DATE: 08/08/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
FRAME
START
END
START
END
START
END
12:00-12:30 AM
12"
12"
00-8:30 AM
4:00-4:30 PM
406
407
12:30- 1:00 AM
12th
12th
30-9:00 AM
4:30-5:00 PM
430
431
1:00-1:30 AM
is
- mil
00-9:30 AM
5:00-5:30 PM
502
508
1:30-2:00 AM
154
-5sl
30-10:00 AM
5:30-6:00 PM
537
538
2:00-2:30 AM
220
221
0:00-10:30 AM
6:00-6:30 PM
600
600
2:30-3:00 AM
237
238
0:30-11:00 AM
6:30-7:00 PM
635
635
3:00-3:30 AM
3"
3'3
1:00-11:30 AM
7:00-7:30 PM
700
700
3:30-4:00 AM
3ʳᵈ
337
1:30-12:00 AM
7:30-8:00 PM
735
735
4:00-4:30 AM
424
425
2:00-12:30 PM
8:00-8:30 PM
200
800
4:30-5:00 AM
445
446
2:30- 1:00 PM
8:30-9:00 PM
836
836
5:00-5:30 AM
5"
5'3
00-1:30 PM
9:00-9:30 PM
902
Go2
5:30-6:00 AM
55
542
30-2:00 PM
9:30-10:00 PM
936
936
6:00-6:30 AM
620
621
00-2:30 PM
10:00-10:30 PM
108
1009
6:30-7:00 AM
635
636
30-3:00 PM
10:30-11:00 PM
1031
1031
7:00-7:30 AM
700
700
00-3:30 PM
11:00-11:30 PM
1107
1107
7:30-8:00 AM
731
net
30-4:00 PM
11:30-12:00 PM
1131
1131
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019768

=== Page 3 ===
mcc new TORK
MCC NEW YORK
mcc new YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIM HOUSING UNIT
ZA
SPECIAL HOUSING UNIT
TIER-J
DATE:
08/08/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1209
12"
0-8:30 AM
807
808
$:00-4:30 PM
403
403
12:30- 1:00 AM
1243
1244
9:00 AM
8"
8ʳᵈ
1:30-5:00 PM
434
435
1:00-1:30 AM
112
13
10-9:30 AM
906
907
5:00-5:30 PM
502
503
1:30-2:00 AM
151
152
10-10:00 AM
9rm
945
5:30-6:00 PM
534
534
2:00-2:30 AM
27
218
00-10:30 AM
1015
10th
6:00-6:30 PM
603
603
2:30-3:00 AM
ret
235
30-11:00 AM
1033
1034
3:30-7:00 PM
632
632
3:00-3:30 AM
30s
30
00-11:30 AM
11°3
1104
7:00-7:30 PM
703
704
3:30-4:00 AM
333
334
30-12:00 AM
11th
1144
7:30-8:00 PM
732
732
4:00-4:30 AM
421
422
00-12:30 PM
1205
12
8:00-8:30 PM
805
806
4:30-5:00 AM
442
443
30-1:00 PM
1238
1231
30-9:00 PM
832
833
5:00-5:30 AM
505
507
00-1:30 PM
107
107
9:00-9:30 PM
905
955
5:30-6:00 AM
538
539
30-2:00 PM
155
156
9:30-10:00 PM
Page
932
6:00-6:30 AM
623
Ing
00-2:30 PM
202
200
10:00-10:30 PM
1002
1002
6:30-7:00 AM
632
is
30-3:00 PM
23ʳ
239
10:30-11:00 PM
1035
1035
7:00-7:30 AM
7"
704
00-3:30 PM
306
307
1:00-11:30 PM
1103
1104
7:30-8:00 AM
735
30-4:00 PM
333
334
1:30-12:00 PM
2E'l
1136
MORNING WATCH
DAY WATCH
VENING WATCH
OPERATIONS
OPERATIONS
PERATIONS
LIEUTENANT
LIEUTENANT
EUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice ner hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minute
ons must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019769

=== Page 4 ===
MCC AEW TORK
MCC NEW YORK
mcc new YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZA
SPECIALHOUSMG UNIT
TIER-K
DATE:
08/08/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
FRAME
START
END
START
END
START
END
12:00-12:30 AM
12"
12"3
0-8:30 AM
809
810
4:00-4:30 PM
404
404
12:30- 1:00 AM
1244
1245
-9:00 AM
8"3
8ʳᵈ
4:30-5:00 PM
433
433
1:00-1:30 AM
13
14
0-9:30 AM
gon
910
5:00-5:30 PM
504
504
1:30-2:00 AM
152
133
0-10:00 AM
988
931
5:30-6:00 PM
535
535
2:00-2:30 AM
218
219
00-10:30 AM
10"
10"
6:00-6:30 PM
602
602
2:30-3:00 AM
sal
234
30-11:00 AM
1039
1040
6:30-7:00 PM
633
633
3:00-3:30 AM
307
309
00-11:30 AM
11
1102
7:00-7:30 PM
702
702
3:30-4:00 AM
334
335
30-12:00 AM
1140
11"
7:30-8:00 PM
733
733
4:00-4:30 AM
422
Ezh
00-12:30 PM
1216
12"
8:00-8:30 PM
803
you
4:30-5:00 AM
443
444
30. 1:00 PM
1230
1231
8:30-9:00 PM
833
834
5:00-5:30 AM
5"
59
0-1:30 PM
101
102
9:00-9:30 PM
904
904
5:30-6:00 AM
537
540
0-2:00 PM
133
134
9:30-10:00 PM
933
934
6:00-6:30 AM
622
63
0-2:30 PM
2.5
206
10:00-10:30 PM
1003
1004
6:30-7:00 AM
633
6
hag
34
0-3:00 PM
237
238
10:30-11:00 PM
1033
1034
7:00-7:30 AM
703
703
0-3:30 PM
302
3'0
11:00-11:30 PM
1105
1105
7:30-8:00 AM
734
734
0-4:00 PM
3"
342
11:30-12:00 PM
1135
1135
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least
se rounds are to be
conducted on an irregular schedule and no more than 40 minutes
ns must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019770

=== Page 5 ===
moc new YORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
secoim HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
M-TIER
DATE: 08/08/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
FRAME
START
END
START
END
START
END
12:00-12:30 AM
1207
1209
0-8:30 AM
g.os
800
4:00-4:30 PM
402
402
12:30- 1:00 AM
1242
12th
0-9:00 AM
821
834
4:30-5:00 PM
435
436
1:00-1:30 AM
1"
112
0-9:30 AM
90'
908
5:00-5:30 PM
501
<06
1:30-2:00 AM
150
1st
0-10:00 AM
8"
9"
5:30-6:00 PM
532
533
2:00-2:30 AM
216
217
00-10:30 AM
10's
10"
6:00-6:30 PM
604
604
2:30-3:00 AM
233
23d
30-11:00 AM
1094
1045
6:30-7:00 PM
631
631
3:00-3:30 AM
302
305
00-11:30 AM
11"
11
7:00-7:30 PM
705
705
3:30-4:00 AM
337
333
30-12:00 AM
113
1132
7:30-8:00 PM
731
731
4:00-4:30 AM
420
421
00-12:30 PM
120s
1204
8:00-8:30 PM
80n
807
4:30-5:00 AM
44'
442
30-1:00 PM
1235
1236
8:30-9:00 PM
831
832
5:00-5:30 AM
503
505
0-1:30 PM
107
18
9:00-9:30 PM
906
906
5:30-6:00 AM
537
55
0-2:00 PM
Be
140
9:30-10:00 PM
931
931
24
6:00-6:30 AM
6-5
0-2:30 PM
2"
2"
10:00-10:30 PM
1001
1002
6:30-7:00 AM
6
632
0-3:00 PM
2.85
234
10:30-11:00 PM
1036
1034
7:00-7:30 AM
705
705
0-3:30 PM
305
306
11:00-11:30 PM
loll
1102
7:30-8:00 AM
736
736
0-4:00 PM
3'
338
11:30-12:00 PM
1138
1138
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twic
rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart
must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019771

=== Page 6 ===
acc new YORK
mcc new TORK
MCC NEW YORK
SPECIAL HOUSING UNIT
SPECIAL HOUSING WAIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
L-TIER
DATE: 08/08/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1205
1207
0 AM
801
802
4:00-4:30 PM
4"
401
12:30- 1:00 AM
1241
1242
00 AM
831
832
4:30-5:00 PM
437
437
1:00-1:30 AM
110
1"
0 AM
900
902
5:00-5:30 PM
500
30$
500
Pm
1:30-2:00 AM
149
150
00 AM
93'
932
5:30-6:00 PM
531
531
2:00-2:30 AM
215
2"
0:30 AM
10"
10"
6:00-6:30 PM
605
605
2:30-3:00 AM
232
233
1:00 AM
1031
1032
6:30-7:00 PM
630
630
3:00-3:30 AM
300
30h
1:30 AM
110
1102
7:00-7:30 PM
706
707
3:30-4:00 AM
30
3
232
2:00 AM
1131
1132
7:30-8:00 PM
730
730
4:00-4:30 AM
419
420
2:30 PM
12
12
8:00-8:30 PM
808
808
4:30-5:00 AM
440
441
:00 PM
123
1232
8:30-9:00 PM
830
830
5:00-5:30 AM
501
503
0 PM
101
102
9:00-9:30 PM
907
907
5:30-6:00 AM
536
537
0 PM
131
132
9:30-10:00 PM
930
930
5-5
25
26
6:00-6:30 AM
6
6
0 PM
2
202
10:00-10:30 PM
P000
1000
6:30-7:00 AM
630
159
16
I
0 PM
23
232
10:30-11:00 PM
1038
1039
7:00-7:30 AM
705
706
0 PM
300
301
11:00-11:30 PM
1100
(100
7:30-8:00 AM
737
737
0 PM
11:30-12:00 PM
1139
1139
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice ner hour These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apa
t be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019772

=== Page 7 ===
mco new YORK
moc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
SPECIAL HOUSING WAIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZB
DATE: 8/8/19
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
RAME
START
END
START
END
START
END
12:00-12:30 AM
12:00
1203
8:00-8:30 AM
8:25
8:27
4:00-4:30 PM
400
405
12:30- 1:00 AM
1230
12:33
8:30- 9:00 AM
8:46
8:46
4:30-5:00 PM
433
437
1:00-1:30 AM
1:00
103
9:00-9:30 AM
9:12
9:14
5:00-5:30 PM
508
510
1:30-2:00 AM
130
133
9:30-10:00 AM
9:50
9:52
5:30-6:00 PM
532
534
2:00-2:30 AM
200
Lob
10:00-10:30 AM
10:17
10:19
6:00-6:30 PM
605
607
2:30-3:00 AM
250
233
10:30-11:00 AM
10:41
10:43
6:30-7:00 PM
1034
638
3:00-3:30 AM
300
303
11:00-11:30 AM
11:22
11:24
7:00-7:30 PM
707
709
3:30-4:00 AM
330
330
11:30-12:00 AM
11:44
11:46
7:30-8:00 PM
/35
736
4:00-4:30 AM
400
405
12:00-12:30 PM
12:26
12:28
8:00-8:30 PM
802
804
4:30-5:00 AM
430
433
12:30- 1:00 PM
12:40
12:42
8:30- 9:00 PM
830
832
5:00-5:30 AM
500
503
1:00-1:30 PM
1:11
1:13
9:00-9:30 PM
908909
5:30-6:00 AM
530
533
1:30-2:00 PM
1:37
1:39
9:30-10:00 PM
937940
6:00-6:30 AM
600
600
2:00-2:30 PM
2:09
2:11
10:00-10:30 PM
10011005
6:30-7:00 AM
630
633
2:30-3:00 PM
2:50
2:51
10:30-11:00 PM
1034
036
7:00-7:30 AM
100
703
3:00-3:30 PM
3:23
3:25
11:00-11:30 PM
Alll
1113
7:30-8:00 AM
730
722
3:30-4:00 PM
11:30-12:00 PM
3:39
1144
1147
MORNING WATCH
DAY WATCH
ENING WATCH
OPERATIONS
OPERATIONS
ERATIONS
LIEUTENANT
LIEUTENANT
UTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019773


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=== Page 1 ===
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d' I I


c1: EFTA00018546
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018546.pdf
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=== Page 1 ===
From: Bruce Barket <bbarket@barketepstein.com>
To:
(USANYS)"
@usdoj.gov>
Cc:
USANYS)"
Subject: Re: update
Date: Tue, 25 Feb 2020 18:24:37 +0000
That's fine. We will still be a week out
Bruce A. Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country Road (700)
Garden City, NY 11530
Barketepstein.com
(516) 287 7230
On Feb 25, 2020, at 1:20 PM,
(USANYS)
@usdoj.gov> wrote:
Bruce,
We will be in a better position to answer your question tomorrow and will plan on getting back to you then. Hopefully,
that does not cause too much of an inconvenience.
Thanks,
Margery
From: Bruce Barket <bbarket@barketepstein.com>
Sent: Monday, February 24, 2020 1:20 PM
T
(USANYS)
@usa.doj.gov>
Subject: update
Good afternoon,
I am writing because my trial which was supposed to begin today has been moved to March 3ʳᵈ. I asked the Court
(EDNY) for March 4th off so I would be able to attend the status conference for Mr. Tartaglione and I explained briefly
that there was a Curcio issue. That application was denied.
So, I am wondering if you will be requesting more time to continue to review material and presumably get input from
our firm. If so, then it may make sense to adjourn the conference. If you don't need more time, then I may make
another request or ask Judge Karas to help. I don't think there is much else that will be done next week other than
address the Curcio issue.
Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
EFTA00018546

=== Page 2 ===
(516) 745 1500 [P] (516) 745 1245 [F]
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00018547


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c3: VOL00008
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Date: Mon, 21 Dec 2020 14:53:04 +0000
Embedded: URGENT_REQUEST_FOR_VTCs-GHISLAINE_MAXWELL_02879-509.msg
Sender:
Subject: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Message-Id: <A00F7D4E-E108-4730-A8F3-A9AD52ED4404@mac.com>
Recipient:
EFTA00019306


c1: EFTA00017846
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c3: VOL00008
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=== Page 1 ===
From:
To:
Subject: 6/28/19, Stan VM, non-substantive
Date: Thu, 02 Sep 2021 03:38:22 +0000
Attachments: voicemail-4.m4a
Stan recounting possible mediation with Epstein and Scott Link and
Sent from my iPhone
EFTA00017846


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c3: VOL00008
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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell
Date: Mon, 13 Jul 2020 19:12:27 +0000
Attachments: 6653181._Maxwell_Ghislaine.pdf
Good Afternoon-
Bail report attached for Ms. Maxwell who is scheduled to appear remotely before Your Honor tomorrow.
copied above completed the Pretrial interview/report and will dial in for this hearing. She can be contacted at
if needed.
Counsels-
In accordance with Local Rule 57.1, Pretrial Services Reports are made available to
Defense Counsel and the Government. The Pretrial Reports are not public record,
are not to be reproduced or disclosed to any other party, and shall remain
confidential as provided in Title 18 U.S.C. $ 3153(c)(1). Please shred, delete and
refrain from forwarding any bail reports received by Pretrial Services.
U.S. Pretrial Services Officer Specialist - Intake Coordinator
Southern District of New York
Office:
Fax:
EFTA00019470


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-770 United States of America V. Maxwell "Defective Document FILED"
Date: Mon, 05 Apr 2021 19:20:21 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/05/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
DEFECTIVE DOCUMENT, Acknowledgment and Notice of Appearance, [32], on behalf of Appellant Ghislaine
Maxwell, FILED.[3070417] [21-770]
Notice will be electronically mailed to:
The following document(s) are associated with this transaction:
Document Description: Defective_Document_Notice
Original Filename:
/opt/ACECF/live/forms/TammyTorres_21770_3070417_Defective_Document_Notice_142.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/05/2021] [FileNumber=3070417-0]
[82ac9d6638f4343e945c759f77acc6c8e4e4d8343df706156a85e0abeacb8b5b67869ed37fa359c625853ed7b4b22
b5ad7f3705c9d7151eb0697a6f103035bae|]
Recipients:
EFTA00018230

=== Page 2 ===


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c3: VOL00008
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=== Page 1 ===
From:
"
(IMD) (FBI)"
To:
"
)"
Cc:
"
)"
(NY)
(FBI)"
>, "Byrne, Paul (NYPD)"
i
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein investigation
Date: Mon, 26 Oct 2020 19:57:30 +0000
Embedded: RE:_Epstein_investigation.msg
Sender:
Subject: RE: Epstein investigation
Message-Id:
<SN1P110MB017599AAF5C69FE0846B1130EC190@SN1P110MB0175.NAMP110.PROD.OUTLOOK.COM
>
Recipient:
EFTA00018597


c1: EFTA00018651
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018651.pdf
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c0:
=== Page 1 ===
From:
To:
Subject: Re: FW: RE:
Date: Fri, 30 Nov 2018 19:31:17 +0000
Importance: Normal
Ok
Sent from my iPhone
On Nov 30, 2018, at 2:11 PM,
wrote:
July 2001. Talked to
briefly before coming here. I can't join the 3:30 but keep me posted!
Kim
Assistant United States Attorney
Southern District of New York
212-637-2038
On Nov 30, 2018, at 1:56 PM,
wrote:
Agreed. Remind me of what we said regarding SOL in Cosby?
Sent from my iPhone
On Nov 30, 2018, at 1:52 PM,
wrote:
I think we should be on this. It's trafficking.
From:
(USANYS)
Sent: Friday, November 30, 2018 1:44 PM
To:
is
Cc:
(USANYS)
Subject: FW: RE:
Hey guys,
We've had a bunch of discussions with brass in last day about this and assigned
to look at things,
including what effect (if any) the Florida NPA has on us (legally it turns out none). Meant to loop you in today - let's
also chat separately.
From:
(USANYS)
Sent: Friday, November 30, 2018 1:39 PM
To:
A. (NY) (FBI)
Cc:
>;
(USANYS)
is
(USANYS)
is
A. (NY) (FBI)
Subject: Re: RE:
EFTA00018651

=== Page 2 ===
Either of those times work for me.
and I have a meeting at 2 so 3:30 would be better if possible.
Sent from my iPhone
On Nov 30, 2018, at 1:35 PM,
A. (NY) (FBI)
wrote:
All,
We've been able to gather some information on the Jeff Epstein matter and I'd suggest we have a call to determine
the way forward. Does 3:00 or 3:30 today work?
From:
A. (NY) (FBI)
Sent: Thursday, November 29, 2018 4:40 PM
To:
A. (NY) (FBI)
Subject: FW:
From:
(USANYS) [mailto:
Sent: Thursday, November 29, 2018 1:36 PM
To:
A. (NY) (FBI)
Cc: Kim,
(USANYS) 4
Subject:
Have you seen this article?
https://www.miamiherald.com/news/local/article220097825.html
Have any insight? From the article is sounds like he cooperated in a financial fraud case and was non-prosd.
and I can chat whenever.
Thanks,
Assistant United States Attorney
Human Trafficking Co-Coordinator
Violent & Organized Crime
Southern District of New York
EFTA00018652


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=== Page 1 ===
From:
To:
Subject:
Date: Mon, 08 Apr 2019 20:23:43 +0000
Importance: Normal
Hey-can we update the Epstein Universe with victim attorney information? I can't tell if that's already done, because the
doc is checked out, but it's hard to keep them straight otherwise, and I don't want to go by memory/emails, because the
volume of witnesses is just going to be really high. Thanks.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019554


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: RE: GM - Letter re Warden
Date: Tue, 01 Dec 2020 20:15:35 +0000
Attachments: 020-12-01_GM_letter_regarding_defense_request_re_MDC_warden_v1.docx
I'm back at my desk. I can send this along to the chiefs. I just added quotes around her statement in the attached. If you
have something else in mind, let me know!
From:
Sent: Tuesday, December 01, 2020 1:38 PM
To:
is
(USANYS)
Subject: RE: GM - Letter re Warden
Agree with your proposal,
Otherwise nothing from me. Thanks very much.
From:
Sent: Tuesday, December 1, 2020 1:27 PM
To:
(USANYS)
Cc:
Subject: Re: GM - Letter re Warden
Sure, no problem.
any comments?
Sent from my iPhone
On Dec 1, 2020, at 1:20 PM,
(USANYS)
wrote:
If you guys want to make any edits you like and then send to the chiefs, that's fine with me. I'm not sure when l'll be
done here
On Dec 1, 2020, at 12:48 PM,
wrote:
Hi
Thanks so much for drafting - I think my only suggestion would be to tweak the language a little bit to make it more
obvious that the language from Bobbi is a direct quote from them/ that they wrote it (and that we aren't just
characterizing their view).
Thanks!
From:
(USANYS)
Sent: Tuesday, December 1, 2020 12:45 PM
To:
is
Subject: GM - Letter re Warden
Hi - I didn't have as much time to work on this as I had hoped before I have to leave the office, but wanted to get the
draft circulating. Sorry about that. Please feel free to edit as much as you like. Saved in the correspondence folder,
and attached.
EFTA00019926

=== Page 2 ===
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00019927


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: State Attorney's Office - New Document Available - Case No 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:45:50 +0000
Sounds good.
Thank you.
Executive Secretary to
Office of The State Attorney, 15th Judicial Circuit
West Palm Beach, FL 33401
From:
Sent: Monday, September 14, 2020 3:45 PM
To
Cc:
Subject: Re: State Attorney's Office - New Document Available - Case No 2020PR000426AMB
Thank you. The paralegal on the case, who is cc'd here, will download the documents.
On Sep 14, 2020, at 3:41 PM,
wrote:
There is a new file available.
Case Number 2020PR000426AMB
Defendant Name JEFFREY E EPSTEIN
Please click here[protect2.fireeye.com] to download the file.
When setting up initial account, please be sure to check your spam/junk email folder for the notification email.
Sent By
Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available
to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure.
EFTA00019643


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=== Page 1 ===
From:
To:
Subject: Note to file
Date: Mon, 31 May 2021 15:43:51 +0000
Attachments: voicemail-193.m4a
Received the attached voicemail. Before I listened, the caller called back and I answered. He gave his name and
said he wanted to talk about treason, Epstein, and Maxwell. I said I couldn't discuss it and he should call our
main line.
Assistant United States Attorney
Southern District of New York
One Saint Andrews Plaza
New York, NY 10007
EFTA00019222


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
:
)"
Subject: RE:
)
- Epstein
Date: Mon, 08 Mar 2021 18:53:09 +0000
Me too
From:
Sent: Monday, March 08, 2021 1:29 PM
To:
is
(USANYS)
Subject: RE:
)
- Epstein
I'm open tomorrow morning.
From:
Sent: Monday, March 8, 2021 1:28 PM
To:
)
is
(USANYS)
Subject: FW:
- Epstein
Are one or more of you free tomorrow morning before 11? Sounds like this will be quick.
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 2, 2020, at 11:09 AM,
)
wrote:
EFTA00017962

=== Page 2 ===
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation with our
investigation, and her status from our perspective has not changed. We'll be in touch going forward, and
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
y.
Subject: Re:
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need anything from us, let us
know.
-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 Feb 21, 2020, at 3:53 PM,
)
wrote:
Joe,
We very much appreciated that, and we just wanted to let you know that the lack of communication separate from
that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch again when we're able.
thanks again,
From: Joe Nascimento
Sent: Wednesday, February 19, 2020 15:03
To:
EFTA00017963

=== Page 3 ===
Cc:
is
Subject: Re:
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light to share
name and information provided with anyone necessary in your investigation. We will wait to hear from you if
you need anything further.
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: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you earlier, but our
investigation is currently still ongoing, so at the very least we wanted to let you know that we continue to appreciate
both your client's prior assistance and her willingness to assist in the future. Nothing in our investigation since we
were last substantively in touch has changed our view of your client, and we hope to be able to be in touch with you in
the coming weeks with an update. In the interim, we do continue to view her status as we've previously conveyed,
and please let us know if any issues arise on your end.
thank you,
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
)
is
Subject: Re:
- Epstein
Hi Joe,
EFTA00017964

=== Page 4 ===
Thanks for checking in-
,
so no issues on our end, but we appreciate your
following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
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 Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on Okeechobee
Blvd. My cell is
when you arrive. My colleague,
will be joining us, and he
can be reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
EFTA00017965

=== Page 5 ===
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:
Cc:
>;
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or 13th
work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00017966

=== Page 6 ===
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
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 I'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
EFTA00017967

=== Page 7 ===
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,
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,
EFTA00017968

=== Page 8 ===
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.
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.
EFTA00017969

=== Page 9 ===
fully transparent with the Government. She understands the likely need to postpone/cancel any personal
travel plans for the time being.
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:
)"
N
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you could
please let us know if there are any particular weeks that would not work for you or your client for a
meeting in Florida (in particular, we don't want to interfere with anyone's summer vacation plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it would
be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
)
Cc:
is
)
Subject: Re:
)
- Epstein
Hi
,
That works for me. Please call me on my cell
Thanks.
Sent from my iPhone
EFTA00017970

=== Page 10 ===
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,
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.
EFTA00017971

=== Page 11 ===
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
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
EFTA00017972

=== Page 12 ===
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:
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
EFTA00017973

=== Page 13 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 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
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/
EFTA00017974

=== Page 14 ===
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.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
)
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)
<mailto:
mailto:
Subject: Re:
)
- Epstein
EFTA00017975

=== Page 15 ===
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. 3<x-apple-data-detectors.//2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-apple-
data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com><http/www.crimlawfirm.com/
On Jul 7, 2019, at 4:04 PM,
)
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I
expect our schedules may be somewhat unpredictable tomorrow; would it work to set a time
to talk on Tuesday? We can schedule it for before you meet with
,
if that's helpful.
Or if you'd like to talk sooner, we could schedule a time later today, or check in tomorrow
about a possible afternoon discussion. Please let us know what you prefer, and we look
forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
EFTA00017976

=== Page 16 ===
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
<mailto:
<mailto:
i
<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. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-
data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com http://www.crimlawfirm.com/
EFTA00017977


c1: EFTA00020401
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020401.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24
ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
:
SUPERSEDING INDICTMENT
:
- V. -
:
S2 20 Cr. 330 (AJN)
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 2004, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2. As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00020401

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 2 of 24
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein. Additionally, between in or about 1994 and in or about
2004, MAXWELL was paid by Epstein to manage his various
properties.
4. Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a.
MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
2
EFTA00020402

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 3 of 24
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b. Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
C.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d. In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
3
EFTA00020403

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 4 of 24
indebted and believed that MAXWELL and Epstein were trying to
help them.
e. Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5. Between approximately in or about 1994 and in or
about 2004, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a. A multi-story private residence on the Upper
East Side of Manhattan, New York owned by Epstein (the "New York
Residence").
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence").
C. A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence").
d.
MAXWELL's personal residence in London,
England.
4
EFTA00020404

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 5 of 24
6.
Additionally, beginning at least in or about
2001, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein
enticed and recruited, and caused to be enticed and recruited,
minor girls to visit Epstein's Palm Beach Residence to engage in
sex acts with Epstein, after which Epstein, MAXWELL, or another
employee of Epstein's would give the victims hundreds of dollars
in cash. Epstein and MAXWELL encouraged one or more of those
victims to travel with Epstein with the intention that the
victim engage in sex acts with Epstein. Moreover, and in order
to maintain and increase his supply of victims, Epstein,
MAXWELL, and other Epstein employees also paid certain victims
to recruit additional girls to be similarly abused by Epstein.
In this way, Epstein and MAXWELL created a network of underage
victims for him to sexually exploit.
7.
Between at least in or about 2001 and in or about
2004, GHISLAINE MAXWELL, the defendant, and Epstein encouraged
and enticed one or more minor victims to engage in paid sex acts
with Epstein through a variety of means and methods, including
but not limited to the following:
a.
Epstein's employees, including, at times,
MAXWELL, would call a victim to schedule an appointment for the
victim to massage Epstein at his Palm Beach Residence. MAXWELL
placed at least some of those calls while with Epstein in
5
EFTA00020405

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 6 of 24
Manhattan, New York. Epstein would often travel from New York
to Florida, where he would then have the scheduled appointments.
b. When a victim initially arrived at the Palm
Beach Residence, she would be greeted by an employee of
Epstein's, including, at times, MAXWELL. The victim would then
be escorted to a room with a massage table. Once inside, the
victim would provide a nude or semi-nude massage for EPSTEIN,
who would himself typically be naked. During these encounters,
EPSTEIN would escalate the nature and scope of the physical
contact to include sex acts such as groping and direct and
indirect contact with the victim's genitals. EPSTEIN would also
typically masturbate during these encounters, ask the victim to
touch him while he masturbated, and touch the victim's genitals
with his hands or with sex toys.
C. In connection with each sexual encounter,
Epstein or one of his employees or associates, including, at
times, MAXWELL, paid the victim in cash. Each victim was
typically paid hundreds of dollars for each encounter.
8. GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
6
EFTA00020406

=== Page 7 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 7 of 24
placing a sex toy such as a vibrator on a victim's genitals,
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
9.
Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, Minor Victim-3, and Minor
Victim-4. In particular, and during time periods relevant to
this Indictment, MAXWELL engaged in the following acts, among
others, with respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
7
EFTA00020407

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 8 of 24
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b. MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
8
EFTA00020408

=== Page 9 ===
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2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
C. MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
d. Minor Victim-4 was recruited to provide
Epstein with sexualized massages for which Minor Victim-4 was
paid by Epstein and/or one of his associates, including, at
9
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times, MAXWELL, at the Palm Beach Residence beginning in or
around 2001. MAXWELL met Minor Victim-4 at Epstein's Palm Beach
Residence when Minor Victim-4 was approximately 14 years old.
MAXWELL subsequently interacted with Minor Victim-4 on multiple
occasions at Epstein's Palm Beach Residence, knowing that Minor
Victim-4 was under the age of 18 at the time. During these
interactions, which took place between approximately 2001 and
2004, MAXWELL groomed Minor Victim-4 to engage in sexual acts
with Epstein through multiple means. For example, MAXWELL asked
Minor Victim-4 about her family and other aspects of her life.
MAXWELL also sought to normalize inappropriate and abusive
conduct by, among other things, discussing sexual topics in
front of Minor Victim-4 and being present when Minor Victim-4
was nude in the massage room of the Palm Beach Residence. On
multiple occasions between approximately 2001 and 2004, Minor
Victim-4 provided nude massages to Epstein at the Palm Beach
Residence, during which Epstein engaged in multiple sex acts
with Minor Victim-4. Epstein's employees, including at times
MAXWELL, called Minor Victim-4, including from New York, to
schedule appointments for Minor Victim-4 to massage Epstein.
After each massage, Epstein or one of his employees, including
at times MAXWELL, paid Minor Victim-4 hundreds of dollars in
cash. At some point during this period, both Epstein and
MAXWELL invited Minor Victim-4 to travel with Epstein and
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offered to assist Minor Victim-4 with obtaining a passport for
purposes of such travel, but Minor Victim-4 declined the
invitation. On multiple occasions between approximately 2001
and 2004, Epstein's employees, including at times MAXWELL, sent
Minor Victim-4 gifts, including lingerie, from an address in
Manhattan, New York to Minor Victim-4's residence in Florida.
Epstein and MAXWELL each also encouraged Minor Victim-4 to
recruit other young females to provide sexualized massages to
Epstein. In response, Minor Victim-4 brought multiple females,
including girls under the age of 18, to provide sexualized
massages for Epstein at the Palm Beach Residence. On such
occasions, both Minor Victim-4 and the girl she brought were
paid hundreds of dollars in cash.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
10. In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
11. From at least in or about 1994, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
11
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Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
12. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
13. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
12
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New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d. Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
e. Between in or about 2001 and in or about
2002, when Minor Victim-4 was under the age of 18, MAXWELL and
Epstein invited Minor Victim-4 to travel from Florida to a place
outside of Florida with Epstein.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
13
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=== Page 14 ===
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persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
16. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
17. From at least in or about 1994, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423 (a).
14
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=== Page 15 ===
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18. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 years in
interstate and foreign commerce, with intent that the individual
engage in sexual activity for which a person can be charged with
a criminal offense, in violation of Title 18, United States
Code, Section 2423 (a).
Overt Acts
19. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
15
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=== Page 16 ===
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unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
e.
Between in or about 2001 and in or about
2002, when Minor Victim-4 was under the age of 18, MAXWELL and
Epstein invited Minor Victim-4 to travel from Florida to a place
outside of Florida with Epstein.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
21. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 years
in interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
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=== Page 17 ===
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aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423 (a) and 2.)
COUNT FIVE
(Sex Trafficking Conspiracy)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
23. From at least in or about 2001, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, sex trafficking of minors, in violation of Title 18, United
States Code, Section 1591 (a) and (b).
24. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, in and affecting interstate
and foreign commerce, recruit, entice, harbor, transport,
provide, and obtain, by any means a person, and to benefit,
17
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=== Page 18 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 18 of 24
financially and by receiving anything of value, from
participation in a venture which has engaged in any such act,
knowing that the person had not attained the age of 18 years and
would be caused to engage in a commercial sex act, in violation
of Title 18, United States Code, Sections 1591 (a) and (b) (2).
Overt Acts
25. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 2001 and in or about
2004, Epstein and MAXWELL recruited Minor Victim-4 to engage in
sex acts with EPSTEIN at the Palm Beach Residence, after which
Epstein and, at times, MAXWELL provided Minor Victim-4 with
hundreds of dollars in cash for each encounter. Minor Victim-4
truthfully told both Epstein and MAXWELL her age.
b.
Between in or about 2001 and in or about
2004, Epstein and MAXWELL both encouraged and enticed Minor
Victim-4 to recruit other girls to engage in paid sex acts with
Epstein, which she did.
C. Between in or about 2001 and in or about
2004, Epstein's employees, including at times MAXWELL, sent
Minor Victim-4 gifts, including lingerie, from an address in the
Southern District of New York to Minor Victim-4's residence in
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=== Page 19 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 19 of 24
Florida. For example, on one occasion in or about October of
2002, Epstein caused a package to be sent by Federal Express
from an address in Manhattan to Minor Victim-4 in Florida.
d. On multiple occasions between in or about
2001 and in or about 2004, Epstein, MAXWELL, or one of Epstein's
other employees called Minor Victim-4 to schedule an appointment
for Minor Victim-4 to massage Epstein. For example, in or about
April of 2004 and May of 2004 another employee of Epstein's
called Minor Victim-4 to schedule such appointments.
(Title 18, United States Code, Section 371.)
COUNT SIX
(Sex Trafficking of a Minor)
The Grand Jury further charges:
26. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
27. From at least in or about 2001, up to and
including in or about 2004, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, willfully and
knowingly, in and affecting interstate and foreign commerce, did
recruit, entice, harbor, transport, provide, and obtain by any
means a person, knowing that the person had not attained the age
of 18 years and would be caused to engage in a commercial sex
act, and did aid and abet the same, to wit, MAXWELL recruited,
enticed, harbored, transported, provided, and obtained
19
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 20 of 24
individuals who were less than 18 years old, including but not
limited to Minor Victim-4, as described above, and who were then
caused to engage in at least one commercial sex act with Jeffrey
Epstein, and aided and abetted the same.
(Title 18, United States Code, Section 1591 (a),
(b) (2), and 2.)
COUNT SEVEN
(Perjury)
The Grand Jury further charges:
28. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
29. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you' re talking about.
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 21 of 24
:
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT EIGHT
(Perjury)
The Grand Jury further charges:
30. The allegations contained in paragraphs 1 through
9 of this Indictment are repeated and realleged as if fully set
forth within.
31. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7433, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall.
Q.
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A. No.
Q.
Other than yourself and the blond and brunette
21
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=== Page 22 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 22 of 24
:
:
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
a
I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A.
That is my testimony, that is correct.
Q.
Is it your testimony that you' ve never given
anybody a massage?
A.
I have not given anyone a massage.
a
You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
a
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
FORFEITURE ALLEGATIONS
32. As a result of committing the offense alleged in
Count Six of this Indictment, GHISLAINE MAXWELL, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594 (c) (1), any property, real and
personal, that was used or intended to be used to commit or to
22
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=== Page 23 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 23 of 24
facilitate the commission of the offense alleged in Count Six,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Six, or any property traceable to
such property.
Substitute Asset Provision
33. If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
$ 853 (p) and 28 U.S.C. $ 2461 (c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853; and
Title 28, United States Code, Section 2461.)
FOREPERSON
badrey AUDREY STRAUSS Street
United States Attorney
23
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=== Page 24 ===
Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 24 of 24
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
SUPERSEDING INDICTMENT
S2 20 Cr. 330 (AJN)
(18 U.S.C. §§ 371, 1591, 1623, 2422,
2423(a), and 2)
AUDREY STRAUSS
United States Attorney
Foreperson
24
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
New York, New York 10007
March 14, 2020
BY EMAIL
Jason E. Foy
Foy & Seplowitz LLC
Hackensack, NJ 07601
Montell Figgins, Esq.
Law Offices of Montell Figgins
Newark, NJ 07102
Re:
United States V. Tova Noel and Michael Thomas, No. 19 Cr. 830
Dear Counsel:
We write in response to your discovery request letters, dated January 29, 2020. This letter
and the content herein is designated as "Protected Materials" pursuant to the Protective Order
entered in this matter.
Thomas Request. The Government refers to its prior response to this request, as stated at
the November 25, 2019 pretrial conference.
Noel Requests No. 1-10, 12-13. We note, at the outset, that many of these requests are
extremely broad and pertain to information that does not appear to be relevant to the case. To the
extent material called for by these requests is within the Government's possession and subject to
disclosure at this time, the Government has already disclosed such information to you, including
by letter dated January 24, 2020. To the extent these requests call for information that is not
currently in the Government's possession or which is not subject to disclosure, you identify no
legal basis or authority for these requests, and we are not aware of any authority requiring us to
obtain and/or disclose this information.
Noel Request No. 11. The name of the MCC technician referenced in the Government's
previous letter is Hughwon Daniel.
Noel Request No. 16. The Government has already produced the available video
surveillance in its possession for July 23, 2019 for the Special Housing Unit. The Government
attaches hereto two public filings in United States V. Tartaglione, 16 Cr. 832 (KMK), which
reference these issues.
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=== Page 2 ===
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Noel Requests No. 14-5, 17-23. These requests, in general terms, call for information about
where particular evidence may be located within the discovery produced to date. As you note, you
seek this information to "assist in expediting the ability of the defense to be ready for trial."
Accordingly, with respect to Noel Requests No. 14-15, 17-23, at your request and solely as a
courtesy to aid you in your review of discovery, the Government is providing the information that
follows. The Government's response to your requests should not be used for any other purpose,
nor should it be construed as a representation that only these files or portions of the surveillance
video are potentially relevant to the Government's case or any potential defense, or as a
representation that the identified portions are the only portions of surveillance video that would be
responsive to your requests. The Government expressly reserves the right to identify and/or offer
at trial additional material as probative of any of the issues identified in these requests.
Noel Request No. 14. With respect to August 9, 2019, we direct your attention to the
following video files: CH0080_20190809195956; CH0080_20190809205956,
CH0080_20190809215956; CH0080_20190809225956. With respect to August 10, 2019, the
following
video
files
contain
this
activity:
CH0080_20190809235959;
CH0080_20190810005959;
CH0080_20190810025959;
CH0080_20190810035959;
CH0080_20190810045959; and CH0080_20190810055959.
Noel Request No. 15. While the Government has not conducted a review of every time
Jeffrey Epstein was captured on MCC surveillance during the more than 30 days he was housed
there prior to his death and does not purport to provide such an exhaustive response, as a courtesy
and to aid in your review of the discovery, we direct your attention to the following: on August 9,
2019 Epstein was captured leaving his cell to make a phone call at approximately 18:53:54 -
18:54:46 (CH0080_20190809175956). Epstein was escorted back to his cell at approximately
19:49:25 - 19:49:39 (CH0080_20190809185956).
Noel Request No. 17. We direct your attention to files CH0080_20190809145956 and
CH0080_20190809155956, during approximately 15:45:00 - 16:15:00 on August 9, 2019.
Noel Request No. 18. We direct your attention to files CH0080_20190809205956 and
CH0080_20190809215956, during approximately 19:45:00 - 20:15:00 on August 9, 2019.
Noel Request No. 19. We direct your attention to file CH0080_20190809215956, during
approximately 22:29:00 - 22:34:00.
Noel Request No. 20. We direct your attention to files CH0080_20190809225956
CH0080_20190809235959, during approximately 23:45:00 (August 9) - 00:15:00 (August 10).
Noel Request No. 21. The Government does not presently believe this interaction was
captured by surveillance video.
Noel Request No. 22. The Government refers you to the forensic examination of the
computers used by defendants Noel and Thomas during August 9 to 10, 2019, which were
previously produced in discovery (SDNY_00000021 - SDNY_00000075). The Government also
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=== Page 3 ===
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refers you to the following files during the following times, which show the defendants at the desk
during the periods of time in which they were using computers, as shown by the forensic
examination referenced above: files CH0080_20190809225956, CH0080_20190809235959
CH0080_20190810005959,
CH0080_20190810025959,
CH0080_20190810035959,
CH0080_20190810045959, and CH0080_20190810055959, during approximately (8/9) 23:39:00
- (8/10) 00:15:00, (8/10) 03:54:00 - 03:57:00, (8/10) 04:29:00 - 05:04:00, and (8/10) 05:10:00 -
06:20:00 as to defendant Noel, and approximately (8/10) 00:35:00 - 01:15:00 and (8/10) 06:00:00
- 06:20:00 as to defendant Thomas.
Noel Request No. 23. The Government refers you to files CH0080_20190810005959,
CH0080_20190810015959, and CH0080_20190810025959 during approximately 00:01:00 -
03:15:00 on August 10, 2019.
We are available at your convenience to discuss any further.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
06.20.2018
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=== Page 1 ===
From:
(USANYS)"
To:
)
1"
Cc:
(USANYS)"
Subject: Re: Catch up tomorrow? 10:30?
Date: Tue, 27 Aug 2019 01:14:27 +0000
is our this week, and I have Epstein conference before Berman at that time.
Do you know when the message for
was left? My understanding is that our team connected with someone
in that office late last week, and they agreed to stand down pending the end of our investigation.
Sent from my iPhone
> On Aug 26, 2019, at 9:05 PM,
) 1
wrote:
V
>
V
> Sent from my iPhone
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=== Page 1 ===
Wells Fargo Bank N.A.
Attn: Legal Order Processing Department
1090 Vermont Ave
Washington, DC 20005
Delivered via: Branch Service
Rider
ALL OPEN AND CLOSED ACCOUNTS
Please provide all images of documents in Adobe PDF files on CDs.
Please provide from account inception to present any and records pertaining to the following
accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as
well as custodian, executor or guardian:
A. Please use the following identifiers:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBERS:
B. Records to be produced should include but are not limited to the items listed below:
EFTA00020171

=== Page 2 ===
1. DATA TRANSACTION FILES
2. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions
and/or subtractions to the account and how the account balances are being satisfied on a monthly
basis;
3. Signature cards;
4. Proof of identification (including but not limited to copies of identification used to open the
account);
5. Opening account(s) documents with attachments, including any and all applications, internal
documents generated to open account(s), and identification information or other documentation
provided by Customer; and Customer's email address
6. "Know your customer" documentation;
7. Wire transfer records (incoming and outgoing, and any and all applications and instructions);
8. Safe deposit records, including applications, signature cards, and sign-in records;
9. Trust accounts;
10. Monthly statements;
11. Credit card statements;
12. Bank, travelers, or cashier checks drawn on account or purchased with an account check;
13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks;
14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports,
applications, and payments made on loans;
15. Online banking information- All information regarding the electronic use of banking systems to
include the following: username, registration IP address, online account creation date, online
account status and IP logs/history, MAC addresses and online session times and duration;
16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or
partnership agreements; and
17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text
messages, that reference or concern items (1) through (16), above, and/or any financial interests
involving the individuals and/or entities identified in Section A.
If you have any questions or comments, please contact
Forensic Accountant, a
EFTA00020172


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=== Page 1 ===
From:
To:
Subject: 3500
Date: Sat, 06 Nov 2021 00:28:50 +0000
Attachments: 2021.11.05_Maxwell_Cover_Letter.pdf;
2021.11.05_U.S._v_Ghislaine_Maxwell_3500_Index_(Defense).pdf;
2021.11.05_U.S._v_Ghislaine_Maxwell_Non-Testifying_Witness_Material_(Defense)pdf
2021.11.06_MDC__Maxwel_PASSWORD.docx;2021.11.06_MDC_-
Maxwell_MAIN.docx
Cover letter and indices for defense are attached as well as cover letters for Maxwell. The production is uploaded to USAfx
and is ready for me to share with defense when you let them know it's up (if you could please copy me on the email that'd
be great). I will load the drive for Maxwell tonight and then will drop off at a FedEx store tomorrow.
EFTA00018888


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=== Page 1 ===
FD-1057 (Rev. 5-8-10)
(Overall Document Classification Required)
FEDERAL BUREAU OF INVESTIGATION
Electronic Communication
Title: (U//FOUO) INTERVIEW OF
Date: 12/04/2018
Drafted By: Missing
Case ID #: 31E-MM-NEW
(U) EPSTEIN, JEFFREY
Details:
01/23/2007
was interviewed in the town
of Palm Beach, Florida regarding a federal investigation involving the
sexual exploitation of minors. After being advised of the identity of
the interviewing agents and the nature of the interview,
provided the following information:
was employed as a
Chauffeur/Butler/House Manager for JEFFREY EPSTEIN at EPSTEIN's
residence,
,
in August or
September 2004.
worked for EPSTEIN for approximately six
months.
stated that when EPSTEIN was in town he was an early
riser.
was expected to be available at all times, seeing to
EPSTEIN's needs and the needs of EPSTEIN's guest. When EPSTEIN hired
,
EPSTEIN told
that he had many girlfriends and
that he must be discreet.
salary and the chef's, DAVID
Last Name Unknown (LNU), salary were paid from the New York Office.
hired LOUELLA LNU, the cleaning lady.
was
responsible for paying LOUELLA LNU and the gardener, Jerome LNU. When
EPSTEIN would come to town,
was to have $8000.00 cash, and
$8000.00 in a checking account.
had a visa in his name with
a $3000.00 credit line. The credit card and checking account were both
with Colonial Bank. Another responsibility of
was to keep
$200.00 - $300.00 in each vehicle. He described himself as a human
ATM. Also prior to EPSTEIN's arrival to the residence,
was
to take $100.00 bills and fan them out on a table near EPSTEIN's bed
located upstairs in EPSTEIN's master bedroom.
was also to
place a gun between EPSTEIN's mattress in a holster that was always
positioned between the mattresses. Once EPSTEIN departed the
residence,
would return the weapon to the safe.
stated that there was a manual written by an employee of EPSTEIN on
the duties and responsibilities of each of EPSTEIN's residences.
According to
,
was EPSTEIN's personal assistant.
She would travel everywhere with EPSTEIN.
was not allowed to
address EPSTEIN directly.
would either have to contact
LNU located out of the New York Office or speak with
regarding matters that concerned EPSTEIN.
liked
, but
said that he felt like she had a hard start in life.
said
(Overall Document Classification Required)
EFTA00019024

=== Page 2 ===
(Overall Document Classification Required)
Title: (U//FOUO) INTERVIEW OF
Re: 31E-MM-NEW, 12/04/2018
that Christmas time was hard for
and that she was not fond of
that time of year.
compared
with a female companion
of EPSTEIN,
LNU.
thought
could show a "mean"
side, but
LNU, a "Polish girl", was more naive.
said
that EPSTEIN was trying to make
LNU more sophisticated.
stated that there were many females that would come to the
residence. A lot of the females that traveled with EPSTEIN looked
European or Foreign.
stated that the local girls who visited
the residence appeared to be younger than those that EPSTEIN traveled
with.
was not sure of the local girls' ages. When asked by
the interviewing agent if they were under eighteen,
stated
that he delivered flowers to a girl at Royal Palm Beach High School
and that some of the girls had car pooled together. The interviewing
agent inquired of
if that meant he believed some of the
girls were underage.
nodded his head, affirming that he
believed some of the girls were under the age of eighteen.
stated that EPSTEIN had directed him to purchase roses for a local
female,
was unable to remember her name. The Unidentified
Female (UF) was appearing in a high school drama play.
purchased the roses from Extra Touch Flowers and delivered them to
Royal Palm Beach High School.
also took the same UF to her
residence two or three times.
said that under EPSTEIN's
instruction,
had also rented a vehicle for the UF. He said
it was a Dodge Neon.
stated that he recalled one female that
traveled with EPSTEIN that looked very young. He believed her name was
)
LNU and that she was from California.
remembered
her only staying at the residence on that one occasion.
LNU
enjoyed flying, so
was instructed by EPSTEIN to take
LNU to get a flying lesson.
took
LNU to an airport in
LANTANA, Florida. He believed her full name may be found on documents
that were filled out prior to
LNU receiving the lesson.
said that EPSTEIN overall was a very private individual.
said that EPSTEIN would get massages everyday, sometimes
morning and night.
was asked on occasion by
to pay
the girls for the massage they had provided to EPSTEIN. He would pay
$300.00 or $400.00 dollars from his petty cash.
specifically
remembered paying a masseuse by the name of
LNU.
stated that he did not go upstairs while the girls performed massages
on EPSTEIN. Afterwards though, he would go upstairs and clean up.
He would also throw tissues in the trash and take towels to
be laundered.
(Overall Document Classification Required)
2
EFTA00019025

=== Page 3 ===
(Overall Document Classification Required)
Title: (U//FOUO) INTERVIEW OF
Re: 31E-MM-NEW, 12/04/2018
-
said that he would wear gloves when cleaning
up after a massage.
did not witness any sexual activity
between the females and EPSTEIN.
According to
,
other than receiving massages, EPSTEIN
enjoyed getting ice cream from a local ice cream parlor with the
girls. Under EPSTEIN's direction,
and sometimes
would
take the girls shopping. If EPSTEIN accompanied them he would stay in
the vehicle. The girls would shop, find something they liked, place
the items on hold, and later
would purchase the items.
also had traveled to the Wellington Mall where he bought
other gifts for the girls, i.e. Ipods or MP3 players.
stated
that on occasion, EPSTEIN would allow some of the girls to drive one
of his vehicles.
stated that he had taken messages from
females calling regarding providing massages to EPSTEIN. He also
stated that an older female possibly in her thirties, named
LNU, would call the residence. She would tell
to let EPSTEIN
know that she had females for him.
could provide no other
information about
LNU.
said that GHISLAINE MAXWELL
traveled to the residence with EPSTEIN on occasion.
believed
MAXWELL to be EPSTEIN's girlfriend, at first. However, when other
females accompanied EPSTEIN, MAXWELL would take another bedroom in the
residence.
said that he thought MAXWELL also would try to
find females for EPSTEIN. On one occasion, MAXWELL told
that
there was $30,000.00 in the safe and that was her money.
said that the only male visitor he could recall accompanying EPSTEIN
to the residence was
+
believed
owned a modeling agency possibly named
stated
that he believed EPSTEIN wanted to be the center of attention with his
female companions.
told the interviewing agents that on one
occasion,
was preparing several of the females something to
eat in the kitchen. The females were laughing and appeared to be
having a good time. EPSTEIN entered the kitchen and asked the females
to join him in the other room.
said that he believed EPSTEIN
was jealous.
also stated that he believed many of EPSTEIN's
female companions were looking to make something of themselves and
were seeking EPSTEIN's assistance.
stated that he believed,
in reality, they were accomplishing nothing.
(Overall Document Classification Required)
3
EFTA00019026

=== Page 4 ===
(Overall Document Classification Required)
Title: (U//FOUO) INTERVIEW OF
Re: 31E-MM-NEW, 12/04/2018
(Overall Document Classification Required)
4
EFTA00019027


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=== Page 1 ===
From:
)"
To:
Subject: Automatic reply: Epstein report
Date: Fri, 13 Dec 2019 20:50:12 +0000
I am currently traveling for work. Although I have some access to emails, my responses may be delayed. For urgent matters, please contact the
other AUSA(s) on the case.
EFTA00019837


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell trial fact witness travel
Date: Fri, 19 Nov 2021 21:47:19 +0000
Attachments: Fact_Witness_Travel_Request
for_trial.docx
Hi
Attached please find a fact witness travel request for another witness in the Maxwell trial
We currently
expect she'll testify on
We would like to have her fly in on
and out on the evening of
You already
booked travel for
so I defer to you, but think it would make sense to have her at the same
hotel. Also, just flagging that there is a chance that we will need to change her travel dates and will know more once trial
is underway. Please let us know if you have any questions.
Thanks so much for all of your help!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00019445


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=== Page 1 ===
From:
To:
Subject: Brass Meeting on Epstein
Date: Fri, 06 Dec 2019 23:05:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00018901


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=== Page 1 ===
From:
To:
Cc
Subject: RE: Epstein update
Date: Sat, 10 Aug 2019 20:51:02 +0000
I just looped you in with
GS of c19, which is leading investigation. They seem to be pretty on top of things
and he shared some troubling details, which I can tell you later or you can get from agents. For now, you should be the
USAO POC with C19; we will discuss with brass if that should remain the case.
thinks the call must be a hoax - the
agents have been with OCME and an autopsy is being done.
From:
Sent: Saturday, August 10, 2019 4:22 PM
To:
Cc:
Subject: RE: Epstein update
Yeah. I'll get on top of that shortly.
From:
Sent: Saturday, August 10, 2019 4:21 PM
To:
Cc:
Subject: RE: Epstein update
Sorry but just related on the FBI and DOJ-OIG investigation, can we get a contact at each of those?? I know there's
apparently no AUSA assigned yet to the FBI side, but for example I would want to let FBI and OIG know that someone is
claiming to be at MCC and calling Epstein's associates to have them pick up the body - they'll be more likely to have
traction with BOP than we will.
From:
Sent: Saturday, August 10, 2019 16:20
To:
Cc:
Subject: RE: Epstein update
Yeah of course. In some ways I actually hope this is a hoax because if not, it's completely insane. And I just called
but he didn't pick up.
Separately, and speaking of the FBI investigation, defense counsel also says that they're starting to get people calling them
who claim to have information relevant to Epstein's death, and are wondering if there is an investigative point person to
whom they can direct any such people?
EFTA00019333

=== Page 2 ===
From:
Sent: Saturday, August 10, 2019 16:17
To:
Cc:
Subject: RE: Epstein update
Removing BOP. They should NOT be releasing the body without confirming with FBI and DOJ-IG. Please discuss that with
them.
From:
Sent: Saturday, August 10, 2019 4:14 PM
To:
is
is
Subject: RE: Epstein update
l'll call you separately in a moment, but just in case email is faster, I just received a phone call from defense counsel that a
person close to Mr. Epstein received a phone call from an individual named
(phonetic) who claimed to be
an investigator with the MCC and told the individual that Mr. Epstein's body was ready to be picked up at the hospital and
that the individual could make arrangements for retrieval of the body.
left his phone number as
Can you please confirm whether that individual is in fact with BOP and/or MCC? Defense counsel is understandably
concerned that they (and others with connections with Mr. Epstein) are starting to get hoax or otherwise inaccurate
information through phone calls and emails. And we would again respectfully but urgently request that if there is
information like this that needs to go to representatives for Mr. Epstein, that it come to us so we can pass it along to his
counsel with confidence that it is true and accurate.
(Separately, if it is accurate that BOP / MCC is prepared to release Mr. Epstein's body, his defense counsel is extremely
concerned about whether that has been enough time for a full autopsy and any other investigative steps, and we would
want to confirm that the FBI team addressing this matter has also been informed-but that's only if this is not a hoax,
obviously.)
Please advise as soon as possible, as the individual is waiting to know whether they should take steps to retrieve the body.
thank you,
From:
Sent: Saturday, August 10, 2019 15:56
To:
is
Cc:
Subject: RE: Epstein update
Hi
I'm checking in to see if you're able to provide us with additional information. I'm
when you have a moment.
Thanks,
EFTA00019334

=== Page 3 ===
From:
Sent: Saturday, August 10, 2019 11:42 AM
To:
Cc:
Subject: Re: Epstein update
Hi
MCC Administrators have been in touch with
at the USMS since early this morning. I too have been in touch
with
since a little after 9 am, at which time I shared the limited information I had. The press release is the sum total of
the information we have at this time pending the investigation. I am going into the secure perimeter to see if there is
more information to share, but please be advised that some of what I get may be shared with your office but not further
since it is an open investigation.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
>>>"
)"
> 8/10/2019 11:30 AM >>>
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic information so that we
can relay it to his attorneys who can relay it to his family. When can we expect to get either some sort of statement we can
pass along to counsel as accurate and reliable or have a call with someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP, and given the
BOP press release that was just put out I assume we need to speak with someone there. Please advise.
Thank you.
On Aug 10, 2019, at 10:43,
> wrote:
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be seeing
information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know as soon as possible
the very basic facts, such as time and cause of death at the absolute minimum. It has now been hours since this was
reported publicly. Please advise when we can expect to receive either a written report on those basic facts or when we can
have a call to get that information to relay to his counsel. It is extraordinarily frustrating to have to tell them that we have
less information than the press. Please advise.
Thank you,
EFTA00019335

=== Page 4 ===
On Aug 10, 2019, at 08:46,
> wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
Cc:
is
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00019336


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=== Page 1 ===
LexisNexis®
21-58, United States of America V. Maxwell
US Circuit Court of Appeals - 02nd Circuit
This case was retrieved on 01/27/2021
Header
Case Number: 21-58
Date Filed: 01/12/2021
Date Full Case Retrieved: 01/27/2021
Status:
Misc: (0) 0: ; Appeal
Participants
Litigants
Attorneys
Ghislaine Maxwell
Christian Romeyn Everdell, Assistant U.S. Attorney
Defendant - Appellant
Defendant - Appellant
AKA: Sealed Defendant 1
Cohen & Gresser LLP New York 21st Floor 800 3rd Avenue New
York New York, NY 10022
Cohen & Gresser LLP
800 3rd Avenue
New York, NY 10022
AttorneyLabel: [COR LD NTC Retained]
Bobbi C. Sternheim, Esq., -
Defendant - Appellant
Law Offices of Bobbi C. Sternheim 4th Floor 33 West 19th Street
New York, NY 10011
Law Offices of Bobbi C. Sternheim
33 West 19th Street
New York, NY 10011
AttorneyLabel: [NTC Retained]
Proceedings
Availability
Date
#
Proceeding Text
Details
01/25
NOTICE OF APPEARANCE AS ADDITIONAL
/2021
COUNSEL, on behalf of Appellant Ghislaine Maxwell
and Appellee USA United States of America, FILED.
Service date 01/25/2021 by CM/ECF. [3020547] [21-58]
01/25
NOTICE OF APPEARANCE AS ADDITIONAL
/2021
COUNSEL, on behalf of Appellant Ghislaine Maxwell,
FILED. Service date 01/25/2021 by CM/ECF. [3020548]
[21-58]--[Edited 01/26/2021 by TT]
01/26
ACKNOWLEDGMENT AND NOTICE OF
EFTA00017873

=== Page 2 ===
Page 2 of 2
21-58, United States of America V. Maxwell
Availability
Date
#
Proceeding Text
Details
/2021
APPEARANCE, on behalf of Appellant Ghislaine
Maxwell, FILED. Service date 01/26/2021 by
CM/ECF.[3021043] [21-58]
01/26
/2021
DEFECTIVE DOCUMENT, Acknowledgment and Notice
of Appearance, [11], on behalf of Appellant Ghislaine
Maxwell, FILED.[3021115] [21-58]
01/26
CURED DEFECTIVE ACKNOWLEDGMENT AND
/2021
NOTICE OF APPEARANCE. on behalf of Appellant
Ghislaine Maxwell, FILED.[3021129] [21-58]
01/26
/2021
ATTORNEY, Bobbi C. Sternheim for Appellant Ghislaine
Maxwell, in case 21-58 ADDED.[3021136] [21-58]
01/26
/2021
FORM B, on behalf of Appellant Ghislaine Maxwell,
FILED. Service date 01/26/2021 by CM/ECF [3021312]
[21-58]
Copyright © LexisNexis CourtLink, Inc. All Rights Reserved.
*** THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY ***
End of Document
EFTA00017874


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 01:55:37 +0000
Thanks,
From:
Sent: Sunday, November 28. 2021 11:41 AM
To:
Subject: Re: United States V. Ghislaine Maxwell
opens
Good luck!! Worthy case, and you'll crush it.
Assistant United States Attorney
U.S. Attorney's Office for the Southern District of New York
One St. Andrew's Plaza
New York. NY 10007
On Nov 28, 2021, at 9:59 AM,
wrote:
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
-
One Saint Andrew's Plaza
New York NY 10007
EFTA00019217


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=== Page 1 ===
ack erry
Daniel Siad
is
A 3G T.....
Daniel Siad
Phone Numbers
Mobile:
+
Other:
+
Email Addresses
Email:
Notes


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject:
Date: Mon, 01 Jun 2020 14:00:54 +0000
You gonna join the Epstein call with Civ Dlv? No pressure, just let me know if we should wait
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00019100


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: travel approval request
Date: Fri, 13 Dec 2019 15:18:28 +0000
Yup, I pre-filled out one for you yesterday, and I'll send it to you shortly. Just trying to set up the rest of your colleague's
trips so everything is taken care of before I leave the Office early this afternoon. Thanks for your patience in this matter.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Friday, December 13, 2019 10:16 AM
To:
Cc:
Subject: Re: travel approval request
Sounds good, thanks very much. And if you could please send me any tax forms I need that would be great. Thanks again.
Sent from my iPhone
On Dec 13, 2019, at 10:14,
wrote:
Okay
I know the issue. The TDY needs to be changed to Santa Monica, CA instead of Los Angeles, CA since you're
actually staying in a hotel that's in Santa Monica, CA, which has a per diem of $248. Los Angeles, CA has a per diem of
$181 only. I'll make the amendments and resend your Travel Authorization to Budget ASAP.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Thursday, December 12, 2019 6:02 PM
To:
Cc:
Subject: FW: travel approval request
I've booked my travel in E2 - once again it's saying the hotel is over the per diem, but that's not correct (it's a dollar
under) but let me know if you need any more info. Otherwise should be good to go, thanks!
EFTA00019561

=== Page 2 ===
From:
Sent: Wednesday, December 11, 2019 10:01
To:
Cc:
is
is
i
is
Subject: RE: travel approval request
Approved
From:
Sent: Wednesday, December 11, 2019 9:58 AM
To:
Cc:
y
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
)
V.
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
EFTA00019562

=== Page 3 ===
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
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
EFTA00019563

=== Page 4 ===
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
EFTA00019564


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=== Page 1 ===
From: "
(USANYS)"
To: "
(USANYS)"
Cc:
"
)"
(USANYS)"
i
(USANYS) [Contractor]"
(USANYS)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: Re: https://www.nydailynews.com/new-york/ny-barr-questioned-epstein-cellmate-20210104-
uyez4izqabg2bowemxpsp3hlom-story.html
Date: Tue, 05 Jan 2021 02:11:40 +0000
Embedded: Re: _https:www.nydailynews.com_new-york_ny-bar-questioned-epstein-cellmate
20210104-uyez4izqabg2bowemxpsp3hlom-story.html.msg
Sender:
Subject: Re: https://www.nydailynews.com/new-york/ny-barr-questioned-epstein-cellmate-20210104-
uyez4izqabg2bowemxpsp3hlom-story.html
Message-Id: <F04FFA68-2A19-4CFA-A138-303A16617D21@usa.doj.gov>
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
EFTA00019913


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
July 31, 2019
CONFIDENTIAL
Martin Weinberg, Esq.
Boston, MA 02116
Reid Weingarten, Esq.
Michael Miller, Esq.
Steptoe & Johnson, LLP
New York, NY 10036
Marc Fernich, Esq.
New York, NY 10019
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Counsel:
Please note that the Government is designating this letter as Confidential pursuant to the
Protective Order in the above-referenced case. This letter provides discovery pursuant to Rule
16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."), and seeks reciprocal
discovery.¹
Disclosure by the Government
Based on your request for discovery in this case, enclosed please find copies of the
materials listed in the index below, which materials are stamped with control numbers
USAO_000001 through USAO_004518:
1
In addition to information provided herein, please note that this Office periodically posts content
on social media platforms including Twitter, Facebook and YouTube. Members of the public may
post comments in response to the Office's postings. We do not control these user-generated
comments, nor do we monitor or regularly review such comments. You may directly access these
social media platforms in the event you believe someone may have posted information relevant to
this case.
06.20.2018
EFTA00018618

=== Page 2 ===
Page 2
Description
Bates Range
American Express Records
USAO 000001-USAO 000041
Apple Records
USAO 000042-USAO 000043
Database Searches & Property Records
USAO_000044-USAO_000964
Deutsche Bank Records
USAO 000965-USAO 002252
Epstein Arrest
USAO 002253-USAO 002278
Florida Search Warrant Photos
USAO_002279-USAO_002643²
Florida Search Warrant Walkthrough Video
USAO 002644-USAO 002652
Google Records
USAO 002653-USAO 002660
Microsoft Records
USAO_002661
2019.07.06 & 2019.07.07 Search Photos
USAO 002662-USAO 0034994
2019.07.11 Inventory Search Photos
AO 003500-USAO 003
2019.07.11 Search Photos
USAO_003510-USAO_0041755
Applications & Warrants
USAO 004176-USAO 004380
Reports & Logs
USAO 004381-USAO 004445
SORNA materials
USAO_004446-USAO_004505
Travel Records
USAO 004506-USAO 004518
As noted in footnotes 2 through 5, the Government is designating certain of portions of
these materials as Confidential pursuant to the Protective Order in this Case.
2 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002416,
USAO_2451, USAO_002452, USA_002509, USAO_002530, USA0_002531, USAO_002532,
USAO_002533, USAO_002535, USAO_002536, USAO_002541, USAO_002542,
USAO_002543, USAO_002547, USAO_002548, USAO_002566, USAO_002575,
USAO_002578, USAO_002579, USAO_002580, USAO_002581, and USAO_002624.
3 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002650 and
USAO_002651.
4Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002817,
USAO_002822,
USAO_002824,
USAO_002826,
USAO_002827,
USAO_002833,
USAO_002848, USAO_002849, USAO_002858, USAO_002859, USAO_002933,
USAO_002934, USAO_003142, USAO_003148, USAO_003153, USAO_003154,
USAO_003155, USAO_003156, USAO_003157, USAO_003177, USAO_003179,
USAO_003192, USAO_003193, USAO_003276, USAO_003300, and USAO_003327.
5 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_003729,
USAO_003742, USAO_004029, and USAO_004092.
06.20.2018
EFTA00018619

=== Page 3 ===
Page 3
If you wish to inspect any of the physical evidence referenced in these materials, including
items listed on search inventories, please let us know, and we will make arrangements for you to
do so.
The defendant also made oral statements when he was arrested on or about July 6, 2019.
Notes memorializing those statements are included in this production and are marked with control
number USAO_002273.
The Government recognizes its obligations under Brady V. Maryland, 373 U.S. 83 (1963),
and its progeny. Pursuant to those obligations, we are disclosing the information below. This
disclosure should not be taken to indicate that the Government believes the enclosed information
constitutes Brady material. Rather, we make this disclosure in an abundance of caution.
Specifically, the Government discloses the following:
The victim identified in the Indictment as "Victim-1" received a grand jury subpoena
from the Southern District of Florida ("SDFL") in or about 2008. However, Victim-1
was never interviewed by law enforcement, including the West Palm Beach Police
Department, Federal Bureau of investigation ("FBI") or SDFL in connection with their
investigation, and Victim-1 did not testify before the grand jury in SDFL. Victim-1 was
first interviewed by law enforcement regarding Jeffrey Epstein in or about 2019, after
FBI agents from the New York Field Office working with this Office approached Victim-
1. The victims identified in the Indictment as "Victim-2" and "Victim-3" we both
interviewed by law enforcement in connection with the SDFL investigation in or around
2007. Please note that all three of these victims are currently represented by counsel.
During an interview with FBI agents in West Palm Beach, Florida in or around 2007, the
victim identified in the Indictment as "Victim-2" stated that during her first contact with
the defendant, she told the defendant that she had just turned eighteen, when in fact she
was younger than eighteen at the time. In subsequent interviews, Victim-2 has told law
enforcement that the first time she met Epstein, she told him that she was 16, when in fact
she was younger than sixteen. Victim-2 further stated that she brought other victims to
the defendant's residence for sexualized massages. She initially told these victims that
they should tell the defendant that they were older than they in fact were. Over time,
however, Victim-2 stopped telling other victims this because she came to understand that
the defendant had a specific preference for underage girls.
During the Palm Beach Department's investigation of the defendant in 2005, a witness
("Witness-1") disclosed to detectives that the defendant had paid Witness-1 to bring girls
for sexualized massages, and that the defendant told her: "the younger the
better." Witness-1 described bringing multiple girls who were under the age of eighteen
to the defendant's residence in Florida. Witness-1 recalled bringing a girl who was over
eighteen, and that the defendant told Witness-1 that this girl was too old. Witness-1
remarked of the defendant: "He likes the girls that are between the ages of 18 and 20."
Witness-1 is represented by Rita Glavin, Esq.
06.20.2018
EFTA00018620

=== Page 4 ===
Page 4
Government will provide material under Giglio V. United States, 405 U.S. 150, 154 (1972),
and its progeny, in a timely manner prior to trial and consistent with the schedule agreed upon by
the parties or set by the Court.
Disclosure by the Defendant
In light of your request for discovery in this case, the Government hereby requests
reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow
inspection and copying of: (1) any books, or copies or portions thereof, which are in the
defendant's possession, custody or control, and which the defendant intends to introduce as
evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental
examinations and of scientific tests or experiments made in connection with this case, or copies
thereof, which are in the defendant's possession or control, and which the defendant intends to
introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the
defendant intends to call at trial.
The Government also requests that the defendant disclose prior statements of witnesses he
will call to testify. See Fed. R. Crim. P. 26.2; United States V. Nobles, 422 U.S. 225 (1975). We
request that such material be provided on the same basis upon which we agree to supply the
defendant with 3500 material relating to Government witnesses.
Sentence Reduction for Acceptance of Responsibility
This Office will oppose the additional one-point reduction under the Sentencing Guidelines
available for defendants who plead prior to the Government's initiation of trial preparations
pursuant to U.S.S.G. § 3E1.1(b), in the event your client has not entered a plea of guilty six weeks
prior to trial. We will follow this policy whether or not suppression or other pretrial motions
remain outstanding after this date and even if the trial date has not been announced by the Court
six weeks in advance of the trial.
06.20.2018
EFTA00018621

=== Page 5 ===
Page 5
Finally, please be advised that pursuant to the policy of this Office concerning plea offers,
no plea offer is effective unless and until made in writing and signed by authorized representatives
of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not
reduced to writing and signed by authorized representatives of the Office cannot and do not
constitute a "formal offer" or a "plea offer," as those terms are used in Lafler V. Cooper, 132 S. Ct.
1376 (2012); Missouri V. Frye, 132 S. Ct. 1399 (2012).
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
by:
Assistant United States Attorneys
Enclosure
06.20.2018
EFTA00018622


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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 29, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
P.O. Box 329002
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed are discovery materials and Government Exhibits pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Very truly yours,
United States Attorney
by:
s/
Assistant United States Attorneys
(212) 637-2225/2343/2345
Enclosure
EFTA00019058


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Lengthy Letter
Date: Wed, 28 Aug 2019 22:03:33 +0000
Attachments: 2019.08.29_Letter_to_RMB_v2.docx
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00020084


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein Bail Statement
Date: Wed, 17 Jul 2019 21:17:28 +0000
We conferred with
and
they expressed misgivings about making any statements regarding detention and at
this point, we agree.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
Mobile:
Press Office:
EFTA00020342


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 16 Filed 07/09/20
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 7/9/2020
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As discussed in its previous order, the Court will hold an arraignment, initial conference,
and bail hearing in this matter remotely as a video/teleconference on July 14, 2020 at 1 pm.
Members of the press and the public in the United States may access the live audio feed of the
proceeding by calling 855-268-7844 and using access code 32091812# and PIN 9921299#.
Those outside of the United States may access the live audio feed by calling 214-416-0400 and
using the same access code and PIN. These phone lines can accommodate approximately 500
callers on a first come, first serve basis.
The Court will provide counsel for both sides an additional dial-in number to be used to
ensure audio access to the proceeding for non-speaking co-counsel, alleged victims, and any
family members of the Defendant. The United States Attorney's Office should email Chambers
with information regarding any alleged victims who are entitled, pursuant to 18 U.S.C.
§ 3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will then
provide information as to the logistics for their dial-in access.
As the Court described in a previous order, members of the press and public may watch
and listen to the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan
Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19, seating will be
EFTA00020393

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 16 Filed 07/09/20 Page 2 of 2
limited to approximately 60 seats in order to enable appropriate social distancing and ensure
public safety. Counsel for the Defendant and the Government may contact Chambers by email if
there is a request to accommodate alleged victims or family members of the Defendant.
Members of the credentialed in-house press corps may contact the District Executive's Office
about seating. Otherwise, all seating will be allocated on a first come, first serve basis and in
accordance with the S.D.N.Y. COVID-19 Courthouse Entry Program and this Court's previous
order of July 7, 2020. See Dkt. No. 10. If conditions change or the Court otherwise concludes
that allowing for in-person viewing of the video feed at the courthouse is not consistent with
public health, the Court may provide audio access by telephone only.
Any photographing, recording, or rebroadcasting of federal court proceedings is
prohibited by law. Violation of these prohibitions may result in fines or sanctions, including
removal of court issued media credentials, restricted entry to future hearings, denial of entry to
future hearings, or any other sanctions deemed necessary by the Court.
so ORDERED.
Dated: July 9, 2020
New York, New York
Alim D.Nitto
ALISON J. NATHAN
United States District Judge
EFTA00020394


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Issues
Date: Tue, 30 Mar 2021 14:26:05 +0000
Inline-Images: image001.jpg; image002.jpg
Hello
Can we meet tomorrow morning at 10:00 am tomorrow to discuss the below production?
Thank you.
From:
Sent: Monday, March 29, 2021 4:00 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Issues
Thanks very much.
From:
(USANYS) [Contractor]
Sent: Monday, March 29, 2021 3:04 PM
To:
Cc:
is
(USANYS)
Subject: RE: Discovery Issues
Hello
I will send this information to PAE and set up a time for a phone call.
Thank you.
From:
Sent: Monday, March 29, 2021 2:59 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Issues
Hi
We just received the below and attached regarding discovery in the Maxwell case. Many of these questions relate to
productions that PAE prepared. Would you please take a look and let me know when would be a good time this week for
a call to discuss?
EFTA00020434

=== Page 2 ===
Thanks,
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
V.
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY_GM_SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
EFTA00020435

=== Page 3 ===
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
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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.
EFTA00020436


