# docs_fts_content

c1: EFTA00033607
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033607.pdf
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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Saturday, August 03, 2019
Beginning Count: 761
SHU: 77/5
Daily Sensitive Information:
M/W
I/M Melendez #85799-054 at Local Hosp. w/USMS Guards
I/M Benjamin #86463-054 on Psych Obs. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
761
77/5
Operations Lieutenant. The fire alarm and sprinkler system are
operational w/exception of Control Center Fire Panel. PREA
announcement conducted via the Institution Public Address System
and/or Radio. Restraint Equipment Cage inventory conducted. All
equipment accounted for. Metal Detector checks conducted. All
operative w/the exception of Rear Gate/Facilities/R&D. Roof
Check completed. All secure. Temporary Chit Inventory: #1:2;
#2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0
12:00
Institution Count in progress
AM
12:00
NYPD Phone Check #2735
AM
12:08
Body Alarm testing in progress
AM
12:30
Watch Calls cont.
AM
12:31
Body Alarm testing completed
AM
12:37
Good Verbal count announced
AM
12:41
Clear Institution count announced
761
77/5
AM
3:00 AM
Institution Count in progress
3:21 AM
Good Verbal count announced
3:25 AM
Clear Institution count announced
761
77/5
5:00 AM
Institution Count in progress
5:36 AM
Good Verbal count announced
5:48 AM
Clear Institution count announced
761
77/5
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
761
77/5
STG International Terrorist phone calls monitored:
WITSEC inquiry was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 761 SHU: 77; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
CONFIDENTIAL
SDNY_00008831
EFTA00033607

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: D/W - Saturday, August 03, 2019
Beginning Count: 761
SHU: 77/5
D/W
Daily Sensitive Information:
I/M I/M Melendez #85799-054 at Local Hosp w/USMS Guards.
I/M Benjamin #86463-054 on Psych Obs. w/inmate companion
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
761
77/5
Lieutenant. The fire alarm and pump system is inoperable at this
time. Fire Watch is in Progress. Unable to conduct PREA
announcement over the Institution Public Address System, due to,
system malfunction. Restraint Equipment Cage inventory conducted.
All equipment accounted for. Metal Detector checks conducted.
All operative w/the exception of Rear Gate. Roof Check
completed. All secure. Temporary Chit Inventory: #1:0; #2:5;
#3:5; #4:6; #5:6; #6:5; Hosp:0
Daily Hand Stamp :GPKJ /RIGHT HAND
8:00 AM
NYPD Phone Check #1892
8:15 AM
Body Alarm Test Initiated.
8:41 AM
Body Alarm Testing Complete.
10:00 AM
Institution count
10:43 AM
Good verbal announced
10:49 AM
Clear count announced
761
77/5
11:00 AM
Mainline feeding in progress.
12:00 PM
Religious service in progress
1:10 PM
Religious service complete
3:45 PM
Institutional lockdown for count.
761
77/5
4:00 PM
Relieved of duties by Lt.
E/W Operations Lieutenant.
761
77/5
Visitation: 5 SOUTH
Inmates
Adults
Children
Total
13
16
3
32
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Ops Lt
Ending Count: 761 ; SHU:77 ; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
CONFIDENTIAL
SDNY_00008832
EFTA00033608

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHU: 77/
SHIFT-DAY-DATE: E/W Saturday, August 3, 2019
Beginning Count: 761
5
Daily Sensitive Information.
E/W
I/M I/M Melendez #85799-054 at Local Hosp w/USMS Guards.
I/M Benjamin #86463-054 on Psych Obs. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch
Operations Lieutenant. Unable to conduct PREA announcement over
the Institution Public Address System, due to, system malfunction.
4:00 PM
Restraint Equipment Cage inventory conducted. All equipment
761
77/5
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:01 PM
NYPD Phone Check #2031
4:03 PM
Body Alarm testing in progress.
4:14 PM
Body alarm testing completed.
4:37 PM
Good verbal announced.
4:51 PM
Clear institutional count.
761
77/5
6:00 PM
Watch call in progress
6:37 PM
+1 Hospital return; I/M Melendez #85799-054
762
77/5
8:01 PM
Trash run in progress
8:40 PM
Trash run complete
10:00
Institutional count in progress.
PM
10:25
Good verbal count announced.
PM
10:29
Clear institutional count announced.
762
77/5
PM
12:00
continues duties as the M/W Lieutenant.
762
77/5
AM
VISITING:
INMATES
ADULTS
CHILDREN
TOTAL
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
Ops. Lt.
Ending Count: 762 ; SHU: 77; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 00; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
CONFIDENTIAL
SDNY_00008833
EFTA00033609


c1: EFTA00031941
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00031941.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
Subject: RE: Jeffrey Epstein/FOIA matters
Date: Wed, 17 Mar 2021 18:26:54 +0000
Hi
Thanks very much for checking, that's helpful, and glad to know it's just those two cases.
Best,
From:
(USANYS)
Sent: Wednesday, March 17, 2021 1:12 PM
To:
Cc:
>;
(USANYS)
Subject: RE: Jeffrey Epstein/FOIA matters
It appears that we only have 2 FOIA cases on Epstein
NY Times case before Judge Engelmayer and
Radar Online case before Judge Gardephe, 17 Civ. 3956 (PGG).
Please let me know if I can help in any way.
From:
Sent: Tuesday, March 16, 2021 6:09 PM
To:
(USANYS)
Cc:
>;
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
Just following up to see if you found out anything from the civil clerks. Thanks for your help with this.
Best,
On Mar 12, 2021, at 11:22 AM,
wrote:
Thanks,
- Much appreciated.
EFTA00031941

=== Page 2 ===
From:
(USANYS)
Sent: Friday, March 12, 2021 11:18 AM
To:
Cc:
is
(USANYS)
is
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
I am copying
who is handling the main matter before Judge Engelmayer and who likely
would know if there are related FOIAs. I will also ask our civil clerk.
Sent from my iPhone
On Mar 12, 2021, at 10:59 AM,
)
wrote:
Hi
In connection with a criminal discovery matter,
and
and I are trying to find a list of all Jeffrey Epstein-
related FOIA lawsuits that the Civil Division has handled (either pending or historical). Our chiefs suggested that you
might be able to help us generate that list - if you have any guidance or information on how we could track this down,
we'd really appreciate your help. Or if there's someone else we should reach out to in the Civil Division instead, please
let us know.
Thanks so much-
Assistant United States Attorney
Southern District of New York
EFTA00031942


c1: EFTA00032426
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032426.pdf
c6: pdf
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=== Page 1 ===
From:
)"
To:
)"
Subject: Update?
Date: Mon, 09 Sep 2019 22:46:31 +0000
I am leaving shortly. No major news.
returned from her grandfather's funeral.
Epstein: we interviewed one victim today.
MCC: We interviewed an inmate.
If we don't connect, we can talk in the morning.
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
Tel.:
EFTA00032426


c1: EFTA00032854
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032854.pdf
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c0:
=== Page 1 ===
From:
=
:
To:
(USANYS)"
Subject: Accepted:
Date: Mon, 04 Nov 2019 15:23:29 +0000
Importance: Normal
Attachments: unnamed
EFTA00032854


c1: EFTA00032381
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032381.pdf
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=== Page 1 ===
From: Mail Delivery Subsystem <MAILER-DAEMON@DJMDCJC01-PPOINT09.jcots.jutnet.net>
To:
Subject: Returned mail: see transcript for details
Date: Wed, 14 Aug 2019 15:02:39 +0000
Embedded: unnamed
The original message was received at Wed, 14 Aug 2019 15:02:39 GMT
from [10.187.9.62]
The following addresses had permanent fatal errors
(reason: 550 Host unknown)
Transcript of session follows
550 5.1.2
Host unknown (Name server:
:
host not found)
EFTA00032381


c1: EFTA00032096
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032096.pdf
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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
Office of the Inspector General
WARNINGS AND ASSURANCES TO EMPLOYEE REQUESTED
TO PROVIDE INFORMATION ON A VOLUNTARY BASIS
You are being asked to provide information as part of an investigation being conducted by the
Office of the Inspector General. This investigation is being conducted pursuant to the Inspector
General Act of 1978, as amended.
This investigation pertains to:
Jeff elstein FNVestigAtion
This is a voluntary interview. Accordingly, you do not have to answer questions. No
disciplinary action will be taken against you if you choose not to answer questions.
Any statement you furnish may be used as evidence in any future criminal proceedings or agency
disciplinary proceeding, or both.
WAIVER
I understand the warnings and assurances stated above and I am willing to make a statement and
answer questions. No promises or threats have been made to me and no pressure or coercion of
any kind has been used against me.
Office of the Inspector General
Special Agent
8/19/17
Witness
Date
4:03pm
Time
Place
OIG Form III-226/2 (04/23/07) Non-Custodial/Employee
EFTA00032096


c1: EFTA00034022
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00034022.pdf
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=== Page 1 ===
The Inmate Companion called and reported that inmate Epstein said his throat is swollen.
Thanks,
CONFIDENTIAL
SDNY_00009875
EFTA00034022


c1: EFTA00032669
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032669.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Christian Everdell <CEverdell@CohenGresser.com>, 'Laura Menninger'
<Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Thu, 08 Apr 2021 21:42:37 +0000
Inline-Images: image001.jpg
Great, thank you very much. Confirmed for 11am on April 12th. It can be a bit tricky to find the entrance to the
warehouse, so please feel free to call my cellphone
(
)
when you arrive, and I can help direct you.
Best,
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, April 8, 2021 5:22 PM
To:
>; 'Laura Menninger' <lmenninger@hmflaw.com>;
)
;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thanks,
11am is fine. I don't think we will need more time. If for some reason we need to go back later in the
week, we can arrange for another trip to finish up.
From:
)
[mailto:
Sent: Thursday, April 08, 2021 5:19 PM
To: Christian Everdell; 'Laura Menninger';
);
(USANYS)
Cc: Jeff Pagliuca; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Chris,
I am going to be tied up for a bit the morning on the 12th. Would it work on your end to meet at the warehouse at 11am,
please? The warehouse will be open until 4:30pm, though I'm told I can request additional time in advance if you think
the review will take more than 5 ½ hours.
Also, I am working on gathering information in response to Laura's email and expect to be able to respond to it later this
evening.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
EFTA00032669

=== Page 2 ===
New York, NY 10007
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, April 8, 2021 5:06 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work?
Thanks,
Chris
From: Laura Menninger [mailto:Imenninger@hmflaw.com]
Sent: Wednesday, April 07, 2021 4:23 PM
To:
)';
);
(USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
EFTA00032670

=== Page 3 ===
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00032671

=== Page 4 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00032672

=== Page 5 ===
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
)
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
EFTA00032673

=== Page 6 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00032674

=== Page 7 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
EFTA00032675

=== Page 8 ===
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
EFTA00032676

=== Page 9 ===
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
EFTA00032677

=== Page 10 ===
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
EFTA00032678

=== Page 11 ===
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
EFTA00032679

=== Page 12 ===
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00032680

=== Page 13 ===
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
i
(USANYS)
EFTA00032681

=== Page 14 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00032682

=== Page 15 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
-
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00032683

=== Page 16 ===
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
V.
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
EFTA00032684

=== Page 17 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00032685


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Thu, 29 Nov 2018 20:53:39 +0000
Importance: Normal
I reached out
and left a message - will let you know when we connect.
From:
(USANYS)
Sent: Thursday, November 29, 2018 3:27 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
t (USANYS)
>;
(USANYS)
Subject: RE: Epstein
I think you should reach out in the first instance and then have the GS call me. We will want to see how quickly they can
gather the FBI investigative file from the old case. We should think about whether there is an immediate subpoena we
should cut to stake claim?
From:
(USANYS)
Sent: Thursday, November 29, 2018 3:14 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>; Khuzami,
Robert (USANYS)
>;
(USANYS)
Subject: Re: Epstein
Agreed.
On Nov 29, 2018, at 2:58 PM,
(USANYS)
>
wrote:
My view is that we should open on this today, and bring in FBI-NY's sex crimes squad.
please let me know if you
want me to reach out to
or if you prefer to call
(the GS who overseas the squad).
From:
(USANYS)
Sent: Thursday, November 29, 2018 2:53 PM
To:
(USANYS)
is
(USANYS)
V.
(USANYS)
Cc
t (USANYS)
is
(USANYS)
Subject: Epstein
As discussed: https://www.miamiherald.com/news/local/article220097825.html
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
EFTA00032502


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=== Page 1 ===
U.S. Department of Justice
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row, New York, NY
August 10, 2019
MEMORANDUM FOR FILE
METROPOLITAN CORRECTIONAL CENTER
FROM:
k, Unit Manager
SUBJECT:
Inmate Epstein, Jeffery Reg. No. 76318-054
This memorandum is in regards of inmate Epstein, Jeffery Reg. No. 76318-054. On
August 9, 2019, I spoke with inmate Epstein concerning him making a call to his family. I told
inmate Epstein I was leaving the facility around 7:00 p.m. Inmate Epstein agreed to shorten his
attorney visitation to make his social call. I escorted inmate Epstein to Special Housing Unit
around 7:00 p.m. I placed inmate Epstein in the shower on (G) Tier and escorted the phone for
him to make a social call. I placed the phone in the first jack to the left on G tier. Inmate Epstein
explain to me that he didn't have his phone set up to use his Pac and Pin number. I asked inmate
Epstein who he was calling, he stated his mother. I remember dialing a number starting with 347,
but the number was note notated. Inmate Epstein began talking on the phone. I told the staff to
end inmate Epstein's call after 15 minutes. They complied.
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=== Page 1 ===
To:
From:
Sent:
Tue 7/30/2019 8:03:02 AM
Subject: Daily Activities Report/Lieutenants Log....7-29-2019
Daily Activities Report 7-29-2019.docx
LIEUTENANT'S LOG 07-29-2019.docm
CONFIDENTIAL
SDNY_00008805
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
i
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
)"
(USANYS)"
i
)"
Subject: Maxwell superseder prosecution memo
Date: Fri, 19 Mar 2021 19:23:52 +0000
Attachments: 2021.03.18_GM_superseder_memo.pdf; 2020-04-10_GM_prosecution_memo..pdf 2020-
04-28,_perjury_memo.docx
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,
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=== Page 1 ===
From:
"
(OCME)"
To:
. (NY) (OGA)"
Cc:
(OCME)"
(USANYS)"
(OIG)"
(NY) (FBI)"
Subject: Re: Epstein video/autopsy
Date: Thu, 15 Aug 2019 21:29:38 +0000
HI: I've left work for the day and have forwarded this email to
I am scheduled to do autopsies
tomorrow. If
approves, we can approach him about coordinating this.
Sent from my iPhone
> On Aug 15, 2019, at 5:12 PM,
(NY) (OGA)
wrote:
V
>
/
,
V
> It was relayed that either yourself or reps from your office would like to view the surveillance footage on file
for Epstein. The files at this point cannot be viewed outside of FBI space due to software issues. If you would
like to view at 290 Broadway please let me know and I will coordinate.
V V V V
-
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=== Page 1 ===
From:
(USANYS)"
To:
(NY) (OGA) (FBI)"
(USANYS)"
Subject: RE: Epstein interview notes
Date: Fri, 30 Aug 2019 17:36:13 +0000
Thank you!
From
(NY) (OGA)
Sent: Friday, August 30, 2019 1:03 PM
To:
>;
(USANYS)
Subject: Epstein interview notes
Attached are all the interview notes. 302s will be prepared during the week.
-
Forwarded message
From:
@nypd.org>
Date: Aug 30, 2019 12:54 PM
Subject: Scanned from a Xerox Multifunction Device
To:
(NY) (OGA)"
Cc:
Please open the attached document. It was scanned and sent to you using a Xerox Multifunction Printer.
Attachment File Type: pdf, Multi-Page
Multifunction Printer Location: 290 Broadway 9th FL; Joint Bank Robbery T/F
Device Name: P290BWAY-JBRTF-MFD
Scanned from a Xerox Multifunction Device
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=== Page 1 ===
Psych Observation 7/8/19 6 pm until 7/10/19 at 9 am (I/M companion utilized)
CONFIDENTIAL
SDNY_00009716
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=== Page 1 ===
Page 0684
OF
U.S. Department of Justice
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York. New York 10007
Office of the Warden
January 27, 2020
MEMORANDUM FOR HUGH J. HURWITZ, ASSISISTANT DIRECTOR,
REENTRY SERVICES DIVISION
FROM:
KAN Licon-Vitale, Warden, MCC New York
SUBJECT:
Institution Response to Psychological Reconstruction
Inmate Epstein, Jeffrey (76318-054)
This is the response to the psychological reconstruction of inmate Epstein, Jeffrey (76318-054) dated
December 27, 2019.
2. 30 Minute Rounds
The substance of the two hour Captain video review and six hour IDO video review is unclear. Please clarify
the requirement for the Captain and IDO. Additionally, please identify the documentation used to maintain
accountability of the reviews.
Institution Response:
Video review requirements have been instituted by NERO. Specifically, on Tuesday of each week, the
institution is notified by NERO of the date, time, and SHU range in which to download video. The video is a
two hour block. The video is to be reviewed by the Captain. During the reviews the Captain is looking for
strict adherence to the requirements that rounds be conducted at least once during every 30-minute period, not to
exceed 40 minutes between rounds and that all scheduled counts are being conducted in the SHU. The Captain
will then submit an assurance memo to the institutional executive staff and Correctional Services Administrator
(CSA) indicating the designated video footage was reviewed, and corrective actions which were taken for any
deficiencies noted. This memorandum will be submitted to the Regional Office by COB on Friday of that same
week. Institutional Duty Officers (IDOs) are required to review 6 hours of SHU video. The surveillance
footage is downloaded by the institutional SIA and a compact disk is provided to the IDOs for review. The
IDOs are reviewing the video for accuracy of the 30 minute rounds. All reviews are documented in the weekly
IDO Report.
1
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=== Page 2 ===
Page 0685
3. Cellmate Assignments
Documentation exists reflecting the role of the local Psychology Services department in communicating the
importance of Mr. Epstein's status as a sex offender with specific needs to the Associate Warden. This includes
consultation with the Psychology Services Branch in Central Office. The communication chain and decision
making of Executive Staff lacks transparency as there is no documentation of the process or staff members
present when decisions were made about the housing of Mr. Epstein. After the fact explanations may not
accurately reflect what occurred.
Institution Response:
As was noted, there was no documentation indicating Psychology Services was present when housing decisions
were made regarding Mr. Epstein. Psychology services is present at the weekly SHU meeting, Executive Staff
meetings, and weekly Opening and Close-Out meetings. During these meetings, the Chief Psychologist or
Acting Chief Psychologist are present to provide recommendations and feedback to the Executive Staff on
housing concerns regarding inmates with mental health issues or risk factors for suicidality. When an inmate
presents with unique risk factors associated with individuals who have been charged with and/or convicted of a
sex offense, careful evaluation is made with regard to housing these inmates with appropriate cellmates.
Moving forward, a plan has been established to have a sign-in sheet and checklist at these meetings where
housing issues are addressed, indicating who was present and what the housing plan is for these inmates with
psychological concerns. These checklists will be maintained in a binder by the Associate Warden of Programs.
Please see the attached checklist.
4. Documentation Accuracy
Professional responsibility requires taking into account multiple descriptions of an incident as noted
in your response. However, when discrepancies exist these should be compiled and noted in
documentation to decrease the likelihood of conflicting conclusions.
As noted in the reconstruction report, an incident report must be written within 24 hours of having
the information that an inmate likely violated BOP rules. An incident report was written for Mr.
Epstein prior to a determination of whether he engaged in self-directed violence or was assaulted on
July 23, 2019. Staff had ample time to wait for the outcome of the SIS investigation of this incident.
The incident report presumed self-directed violence, although SIS was not able to determine whether
this incident was self-directed violence or an assault. Generating the incident report for self-directed
violence is evidence of a local bias about the July 23, 2019, incident that still exists amongst some
staff at MCC New York. Preconceived notions challenge the ability to remain open about alternative
explanations, and subsequent systemic changes may be needed.
Please develop and provide local training for all staff that at a minimum reviews the time frame for
writing incident reports and offers guidance when there is not clear evidence of an infraction. Include
an outline of the training and evidence of staff who attended the training.
Institution Response:
Additional information (slides) has been included in our Annual Training presentations for Report Writing. In
addition to the established training, the slides further differentiate and provide guidance to staff regarding when
it is appropriate to write an Incident Report and when, in cases of a lack of evidence, a memorandum is more
appropriate. The additional information is being provided to all staff as a part of Annual Training. Annual
Training began the week of January 6, 2020, and will continue through the week of March 8, 2020.
2
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=== Page 3 ===
Page 0686
5. Telephone Calls
As noted in the response, there is a lack of documentation to substantiate that a lieutenant facilitated two
telephone calls to Mr. Epstein. However, this does not address the report of two telephone calls being provided.
This response implies that the reporting of two staff members is inaccurate.
The response neglects the documented telephone call to Mr. Epstein's deceased mother.
Institution Response:
On August 29, 2019, Warden J. Petrucci, signed a referral related to
failure to follow policy in
allowing Epstein to complete an unmonitored phone call. The referral was submitted to the Office of Internal
Affairs on that same date and is pending further action at this time.
7. Follow-Up
Please provide documentation for the follow-up training provided to staff detailing the content of the training
and to whom it was provided.
Institution Response:
As recommended by Central Office, the Chief Psychologist has conducted suicide prevention trainings during
Department Head Meetings, e-mail correspondence, SHU Staff Trainings, and Lieutenant's Trainings. The
follow-up training sign-in sheets, Department Head Meeting Minutes, and e-mails provided by psychology staff
regarding PSY ALERT Inmates are attached for your review.
8. Inmate Accountability and Assignment Accuracy
Periodic and unannounced checks are now conducted in SHU to determine pp30 assignments and actual inmate
placement match. Please provide an operational definition of periodic. Please do the same for routine, as it
relates Executive Staff bed book counts in all units. Where will the periodic and routine reviews be documented
and will they include the identity (e.g., name and title) of staff who complete them?
Institution Response:
An Executive Staff and Duty Officer schedule has been implemented to conduct daily 4 P.M. and 10 A.M.
weekend bed book counts. Any discrepancies noted are documented and sent via email to Unit Mangers and
Captain at the conclusion of each count for corrective action. Please see the attached schedule.
9. Attorney Log Books
Please provide a copy of the log book audit.
Institution Response:
The audit revealed the Random Visitor Log Book did not reflect visitor pat searches after May 19, 2019. In
addition, the log book does not offer a column to annotate a staff witness. The Contractor/Volunteer Log
Book was not always filled in properly. The Law Enforcement Log Book was up to date; however, the time of
departure was not always documented. The Attorney Log was missing inmate register numbers and more often
than not was legible. There was no Visitor Denial Log created. The audit conducted on September 25, 2019, is
attached for your review.
3
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=== Page 4 ===
Page 0687
Additional corrective measures will now include the Activities Lieutenant checking all Front Lobby log books.
The Captain will ensure these checks are included in the Lieutenant's Daily Log for Day Watch and Evening
Watch. In addition, the Activities Lieutenant will address any discrepancies immediately through on the spot
training and/or performance log entries.
13. Sex Offense Risk Factors
Psychologists are subject matter experts in sex offender risk factors and they play a crucial role in sharing this
knowledge through traditional settings such as ICT, AT, and institutional meetings. However, Executive Staff
play a pivotal role in establishing and addressing institutional culture and promoting and participating in
training. A lack of a broad understanding of sex offender specific risk factors requires an intentional training
approach led by Executive Staff. They must be out front talking about inmates with a sex offense, expressing an
understanding of sex offender dynamics, modeling agency condoned expectations for the understanding and
treatment of inmates with a sex offenses, and assisting with institutional trainings. These practices encourage a
broader acceptance by line staff.
Institution Response:
The MCC New York Executive Staff are out front talking about inmates with sex offenses, and expressing an
understanding of sex offender dynamics, modeling agency expectations for the understanding and treatment of
inmates with sex offenses. This is done through departmental meetings, trainings, staff recalls and walking and
talking throughout the institution.
ATTACHED DOCUMENTS:
Institution Duty Officer Report
Cellmate Review
Report Writing "Back to Basics Training"
SHU Suicide Prevention Training
Department Head Meeting minutes
PSY ALERT inmates
Bed Book Count Schedule (Exec Staff/IDO)
Bed Book Audit (emails)
Log Book Audit
Executive Staff List
4
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From:
To:
Cc:
"
"
,
(USANYS)"
Subject:
Date: Thu, 23 Jul 2020 16:07:16 +0000
Attachments: Part_3.zip
Amanda ivroore
Special Agent
FBI New York Field Office
Violent Crimes Task Force
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I'm sorry! I had it checked off that I did it. Maybe I didn't hit enter. Thank you. It was 1:40 AM.
>>>
7/24/2019 10:31 AM >>>
I just went to enter his MDS code and realize you didn't yet enter it. Just want to be sure, is 0140 the start time? I can enter yours and
mine now.
CONFIDENTIAL
SDNY_00009881
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Updated press release with addition of arrival date and official charges.
CONFIDENTIAL
SDNY_00009138
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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell Pardon
Date: Mon, 30 Nov 2020 20:07:16 +0000
ok
From:
)
Sent: Monday, November 30, 2020 3:07 PM
To:
)
;
)
Subject: RE: Ghislaine Maxwell Pardon
Sure. I'll call
and conference you in.
From:
Sent: Monday, November 30, 2020 3:06 PM
To:
)
Subject: RE: Ghislaine Maxwell Pardon
Can we get on a call now?
From:
Sent: Monday, November 30, 2020 2:13 PM
To:
Cc:
)
Subject: FW: Ghislaine Maxwell Pardon
FYI.
From:
Sent: Monday, November 30, 2020 1:49 PM
To:
Cc:
)
Subject: Re: Ghislaine Maxwell Pardon
Thanks, let's just hope it's as off base as it sounds. The reporter is Tom Winter, who correctly reported (even
though it was much easier to predict) the Flynn pardon before it happened.
Sent from my iPhone
On Nov 30, 2020, at 1:45 PM,
wrote:
That's correct.
From:
Sent: Monday, November 30, 2020 1:45 PM
To:
Cc:
Subject: Fwd: Ghislaine Maxwell Pardon
Just FYI. I forget how this went with Di Souza, but there wouldn't necessarily need to be any communication
with us before pardoning one of our defendants, correct?
Sent from my iPhone
Begin forwarded message:
From:
Date: November 30, 2020 at 1:21:36 PM EST
EFTA00032009

=== Page 2 ===
To:
,
Cc:
Subject: Ghislaine Maxwell Pardon
Normally I wouldn't send something like this because it seems so unlikely, but just FYI - a reporter who's
been reliable in the past is hearing "serious rumblings" from the WH about a pardon.
Sent from my iPhone
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=== Page 1 ===
From:
To:
Subject: Prisoner Production Request for Proffer
Date: Tue, 13 Aug 2019 19:00:13 +0000
Embedded: RE: 8 16 Friday Proffer - Efrain_Reyes
,_GEO.msg
Use this e-mail only for requests to produce prisoners for proffers. Please advise if this is a special circumstance
proffer (i.e. visiting agents, visiting attorneys or if trial is within the next five days)
AUSA:
AUSA Phone:
AUSA Cell Phone:
Production Date:
8/16/19
Production Time:
11 am
Production Place: _x_500 Pearl
40 Foley*
Defendant: Efrain Reyes
USMS#:
Defendant's Docket No:
Separatee(s):
USMS#(s):
Cancelling a Production. Prior to noon of the day before the scheduled production, use this email template.
Assistant United States Attorney
Southern District of New York
Tel:
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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com>
To:
Subject: Calls For Probes Intensify After Roger Stone Sentence Fracas
Date: Thu, 13 Feb 2020 08:39:30 +0000
Law360 White
Collar
WHITE COLLAR
Thursday, February 13, 2020
Follow Law360
TOP NEWS
Law360 Practice Groups of the
Analysis
Year
Calls For Probes Intensify After Roger Stone Sentence Fracas
The U.S. Department of Justice's about-face in the Roger Stone case has
fueled calls for investigations into the Trump administration's potential
interference into cases against the president's friends, but political and legal
obstacles may stand in the way.
Read full article
Judge Rejects Roger Stone's Bid For A New Trial
A D.C. federal judge tossed Roger Stone's request for a new trial based on
claims that a biased government employee sat on the jury panel, which found
him guilty on seven felony charges including lying to Congress about
WikiLeaks, according to a court filing unsealed Wednesday.
Order attached Read full article
LAW FIRMS
Aidala Bertuna
Ex-Theranos CEO Escapes Charges She Defrauded Doctors
Akerman LLP
A California federal judge has cut criminal charges alleging former Theranos
Alston & Bird
CEO Elizabeth Holmes and another executive defrauded doctors and insured
patients about the viability of the once high-flying startup's blood-testing
Arent Fox
technology, but left intact most of the indictment, rejecting defense arguments
Arnold & Porter
that it is "unconstitutionally vague."
BakerHostetler
Order attached Read full article
Bass Berry
Berger Montague
Boies Denies He Defamed Dershowitz With Epstein Remarks
Bird & Bird
Prominent litigator David Boies hit back Wednesday against defamation
counterclaims by embattled attorney Alan Dershowitz, saying statements he
Boies Schiller
made about Dershowitz's alleged connection to notorious sex offender
Bradley Arant
Jeffrey Epstein were true and protected by the First Amendment.
Brinks Gilson & Lione
1 document attached Read full article
Brown & Connery
Bruce S. Rogow PA
Boston City Hall Aides Get Extortion Conviction Tossed
Buschel & Gibbons
Two former aides to Boston Mayor Marty Walsh saw their Hobbs Act extortion
Carlton Fields
convictions thrown out Wednesday, as a federal judge said the government
failed to show a clear quid pro quo or "wrongful conduct" for the pair
Collier Halpern
pressuring a music festival to hire union labor.
Cosgrove Eisenberg
Order attached Read full article
Davis Polk
Dentons
Air Charter Co. Execs Can't Slip Fraud Convictions At 3rd Circ.
Gibson Dunn
The Third Circuit has upheld two charter airline executives' convictions for
Goldman Scarlato
stealing millions in passenger payments by lying and falsifying documents,
Goodwin
EFTA00032942

=== Page 2 ===
saying Wednesday that documents found after trial - previously thought
Greenberg Traurig
destroyed - would not have changed the outcome.
Hogan Lovells
Opinion attached Read full article
Holland & Hart
INVESTIGATIONS
Holwell Shuster
Husch Blackwell
Harvard, Yale Probed Over Unreported Foreign Funds
Kellogg Hansen
The U.S. Department of Education has launched investigations into
potentially hundreds of millions of dollars in unreported foreign gifts and
King & Spalding
contracts accepted by Yale and Harvard universities in recent years, the
Kirkland & Ellis
department announced Wednesday.
Lane Powell
Read full article
Latham & Watkins
SECURITIES
Levi & Korsinsky
Linklaters
FTC Targeted Sanctuary Belize To Punish Founder, Judge Told
Lowenstein Sandler
A Federal Trade Commission suit targeting the operators of purported luxury
Mayer Brown
development Sanctuary Belize was sparked by a personal vendetta against
McDermott Will
the project's mastermind - and not legitimate consumer concerns - one of
Morgan Lewis
the executives told a Maryland federal court Wednesday on the last day of
Morrison & Foerster
trial.
Read full article
Munger Tolles
O'Melveny & Myers
PNC Abetted $75M 'Ponzi-Like' Scheme, Investment Cos. Say
Olshan Frome Wolosky
Two investment companies and a Pennsylvania man on Wednesday hit PNC
Orrick
Bank and Heartland Bank & Trust with a proposed class action accusing the
Paul Weiss
banks of aiding and abetting a $75 million Ponzi scheme in which an Illinois
Polsinelli
man allegedly took money from more than 500 investors.
Complaint attached Read full article
Riley Warnock
Robbins Geller
Fund Says Fugitive Ex-Nissan Exec Must Face Securities Suit
Searby LLP
If Nissan Motor Co.'s ex-chairman wanted a federal judge to buy his
Sheppard Mullin
argument that he can't face a securities fraud suit in Tennessee due to an
Sullivan & Cromwell
upcoming trial in Japan, he shouldn't have fled that country in a suitcase, a
Troutman Sanders
pension fund argued Wednesday.
White and Williams
Response attached
Read full article
Williams & Connolly
Glencore Seeks To Dismiss Stock-Drop Suit Over FCPA Probe
WilmerHale
Mining giant Glencore PLC told a New Jersey federal judge that his court's
Winston & Strawn
lack of personal jurisdiction was among the many faults that required
Womble Bond Dickinson
dismissal of a stock-drop suit connected to announcements that the Swiss
company's overseas dealings were being investigated.
COMPANIES
Brief attached Read full article
Alaska Oil and Gas Association
American Bar Association
SEC Sues California Investment Firm Over $1.1M In Side Deals
Center for American Progress
The SEC slapped a California investment firm and its directors with a
Chevron Corp.
securities suit Wednesday, alleging they failed "to disclose a glaring conflict
Coinbase Inc.
of their financial interests" when they advised their clients to invest over $16
million in private placement funds and then pocketed over $1.1 million in side
Consolidated Edison Inc.
deals.
Federalist Society
Complaint attached
Read full article
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sold oxycodone on the Silk Road online drug bazaar to 3½ years in prison
Wednesday after the feds caught him lying about where he had gotten
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bitcoins that had surged in value to $19 million.
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EFTA00032943

=== Page 3 ===
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Texas Doc Fights Claim Of $69M In Unneeded Treatments
Microsoft Corp.
Attorneys representing a Houston-area doctor accused of seeking more than
Mitsubishi Motors Corp.
$69 million in reimbursements for medically unnecessary lead poisoning
National Association for the
treatments tried to show through testimony on Wednesday that a difference
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TAX
Novartis AG
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Export Business Owner Gets 3 Years For Concealing Income
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INTELLECTUAL PROPERTY
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GOVERNMENT AGENCIES
A Texas man will serve 16 months in prison and will forfeit more than
Commodity Futures Trading
$342,000 following his conviction for conspiring to steal trade secrets, U.S.
Commission
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EXPERT ANALYSIS
Federal Trade Commission
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Effective AML, Anti-Bribery Programs Hinge On Collaboration
Judicial Conference of the United
Amid increasing risk exposure from financial services companies' partners,
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clients and affiliates, opportunities exist to leverage processes across firms'
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anti-money laundering and anti-bribery and corruption programs, says
Occupational Safety and Health
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Securities and Exchange
Commission
The U.S. Securities and Exchange Commission's recently released exam
Serious Fraud Office
priorities encourage firms to emphasize investor protection and consider
compliance in light of evolving business and market demands, say attorneys
U.S. Attorney's Office
at Lowenstein Sandler.
U.S. Court of Appeals for the Third
1 document attached
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LEGAL INDUSTRY
U.S. Department of Education
U.S. Department of Health and
Q&A
Human Services
Microsoft Atty Looks To A Legal Future Saved
U.S. Department of Justice
From Drudgery
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U.S. Department of the Interior
Microsoft assistant general counsel Jason Barnwell gives his take
U.S. District Court for the Central
on whether tech will replace lawyers, the challenges of getting them
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for his team's youngest members when they take the helm.
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Massachusetts
Feature
U.S. District Court for the District of
What Law Firm Leaders Say You Should Know
New Jersey
For The Future I
U.S. District Court for the Eastern
District of New York
EFTA00032944

=== Page 4 ===
Here, in front of the camera, law firm leaders talk about how to
U.S. District Court for the Northern
prepare for a future where technology and a new generation of
District of California
talent and competitors will change the way attorneys work.
U.S. District Court for the Northern
Read full article
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Novartis Taps Firms Ready To Pony Up On Diversity - Or Else
U.S. District Court for the Southern
Novartis AG on Wednesday said it has chosen nearly two dozen preferred
District of New York
law firms that have agreed to diverse staffing requirements for each legal
U.S. Marine Corps
matter, with the understanding that the pharmaceutical giant will deny a
U.S. Navy
portion of payment for failing to hit the goals.
U.S. Supreme Court
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White And Male: Federal Bench Still Struggling With Diversity
White men still dominate the bench in U.S. federal courts, and that lack of
diversity could lead litigants to question the federal judiciary's legitimacy,
according to a new study released Thursday, which found that more than a
third of all federal district courts did not have even one nonwhite judge.
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Garland Succeeded By Srinivasan As DC Circ. Chief Judge
Merrick Garland was replaced by Sri Srinivasan on Wednesday as chief
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and, of course, an unsuccessful nomination to the U.S. Supreme Court.
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Judge Weinstein Steps Back From Bench After 53 Years
U.S. District Judge Jack Weinstein, a nonagenarian who worked on the
landmark Brown V. Board of Education case and has sat on the Eastern
District of New York bench since 1967, is effectively retiring, his law clerk
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The White House on Wednesday said it would nominate a Gibson Dunn &
Crutcher LLP litigation partner to the federal trial court in Manhattan and a
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Two BigLaw partners and two other judicial nominees sailed through a
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EFTA00032945

=== Page 5 ===
Law Firm Leaders: Akerman's Scott Meyers
Scott A. Meyers took on the chairman and CEO role at Akerman on Feb. 3,
following up two years serving as the law firm's managing partner. Here,
Meyers discusses why he thinks Akerman is "less bureaucratic" than the
typical BigLaw firm, his goals for the firm's future, and how he approaches
hiring lawyers that are a good cultural fit.
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EFTA00032946


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=== Page 1 ===
To:
From:
Sent:
Thur 8/1/2019 8:19:59 PM
Subject: Epstein, Jeffrey Edward, Reg. No. 76316-054
TEXT.htm
2019 08 01 16 18 51.pdf
Charisma Edge.vcf
Just in case you need a synopsis of his activity
Wed 7/31/19
Rec 6:30 - 7:30 a.m.
Court 9:30 - 11:30 am
Thursday 8/1/19
Atty conference beginning 9:00 am - present
Taken off psych ops on Tues 7/30/19. Seen by psych next day as a standard practice. Suicide Risk
Assessment (SRA) conducted today by Dr.
Findings indicate he is psychologically stable. Per Dr.
SRA was initiated because Epstein returned from court W a note indicating suicidal tendencies.
see attachment
Associate Warden (O)
FCI Estill
100 Prison Road
Estill, SC 29918
CONFIDENTIAL
SDNY_00009169
EFTA00033711


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=== Page 1 ===
I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M companion was utilized).
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
CONFIDENTIAL
SDNY_00009543
EFTA00033874


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=== Page 1 ===
From:
To:
Michael Thomas;
Tova Noel:
Subject:
!!REMINDER!! Know Your Rights
Date:
Monday, August 12, 2019 12:59:05 PM
Attachments:
TEXT htm
Good Afternoon All:
If you are called for an interview by the agency or a representative of the agency (ie. FBI, AUSA, OIA, OIG), you
are required to report the interview. You are required to be truthful.
In line with your Weingarten rights, once at the interview you have the right to request a Union Representative. In
line with the rights afforded to any other US citizen, during a criminal investigation, you have the right to invoke
your 5th amendment right to remain silent until your attorney is present.
Blessings to all.
In Unity!
"I don't cheat to win, I'd rather lose." - Serena Williams
EFTA00032993


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
)"
Cc:
(NY) (FBI)"
Subject: Hotline update
Date: Wed, 10 Jul 2019 02:08:10 +0000
Attachments: HOTLINE_TRACKER_9PM_7.9.2019.xlsx
SSA
FBI New York
EFTA00032703


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=== Page 1 ===
Event: Call with USVI (Epstein)
Start Date: 2020-04-03 15:00:00 +0000
End Date: 2020-04-03 16:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2020-04-02 00:33:07 +0000
Date Modified: 2020-04-02 00:33:07 +0000
Priority: 5
DTSTAMP: 2020-04-01 21:49:11 +0000
Attendee:
(USANYS)
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=== Page 1 ===
From: NYS Academy of Trial Lawyers <noreply@m.nysa.membercentral.org>
To:
Subject: Announcing the Academy's Upcoming Webinars
Date: Fri, 28 May 2021 16:14:29 +0000
Culture Changing Conversations
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EFTA00032414

=== Page 2 ===
For additional assistance, contact the Trial Academy via email.
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=== Page 1 ===
As I was doing the 10:00 PM count, I notice this inmate distraught, sad and a little confused. I asked him if he was ok? he said, "that
he's ok." but I am not convinced because he seems dazed and withdrawn. So just to be on the safe side and prevent any suicidal
thoughts can someone from Psychology come and talk with him. I don't know the inmate register number because he is new, he is
currently on 5 North. I don't know who did his in take, so I am not familiar with any information on this inmate.
CONFIDENTIAL
SDNY_00009748
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=== Page 1 ===
Ok
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
Date: 7/18/19 3:02 PM (GMT-05:00)
To:
V.
Subject: Epstein, Jeffrey Edward, Reg. No. 76318-054
07/18/2019 15:02
FYI Epstein was not granted bail. He returned from court wo incident.
Associate Warden (0)
FCI Estill
100 Prison Road
Estill, SC 29918
EST/AW-Operations-@bop.gov
CONFIDENTIAL
SDNY_00008957
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=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Date: Wed, 10 Jul 2019 02:52:58 +0000
Importance: Normal
Attachments: blank_proffer_agreement.pdf
Joe,
I think that should work, but let us confer internally and we'll circle back tomorrow morning. Meanwhile, attached please
find a blank copy of our standard proffer agreement. Please let us know if you have any questions, or if it would be useful
to talk again in the next day or two, and we'll be in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
Sent: Tuesday, July 09, 2019 22:50
To:
Cc:
in
Subject: Re:
)
- Epstein
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 9, 2019, at 4:56 PM,
)
wrote:
EFTA00032704

=== Page 2 ===
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
Sent: Tuesday, July 09, 2019 16:43
To:
Cc:
is
)
Subject: Re:
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
wrote:
Hi
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p. 305-858-9550
f. 305-858-7491
e.
www.crimlawfirm.com
From:
)"
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
Cc:
)"
)"
=
EFTA00032705

=== Page 3 ===
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on Tuesday - you can reach us at
or we can also call you then if that's easier, whatever you prefer.
thanks,
From: Joe Nascimento
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules
may be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for
before you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today,
or check in tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look
forward to being in touch.
thank you,
EFTA00032706

=== Page 4 ===
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
Sent: Saturday, July 06, 2019 22:55
To:
Subject:
)
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
) - Epstein
My former partner, Alan Ross, represented
), prior to his passing in
2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am
getting up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
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=== Page 1 ===
From:
To:
Subject: Fwd: Epstein memo
Date: Fri, 10 May 2019 17:32:11 +0000
Importance: Normal
Attachments: 2019-05-10_JE_status_memo_for_ODAG.docx; ATT00001.htm; 2019-05-
10_JE_status_memo_for_ODAG.pdf;ATT00002.htm
Sent from my iPhone
Begin forwarded message:
From:
Date: May 10, 2019 at 1:31:10 PM EDT
To: "Strauss, Audrey (USANYS)"
Cc:
Subject: Epstein memo
Audrey - - Attached is a revised (and shortened) memo for ODAG.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
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=== Page 1 ===
Good morning,
Thank you.
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
Date: 7/28/19 7:49 AM (GMT-05:00)
To:
Cc:
Subject: Fwd: Suicide Watch/Psych Observation Update
07/28/2019 07:49
,
Inmate Epstein seems psychologically stable.
He complained that his right arm was numb and hanging earlier. Nurse
saw him.
He again said his right arm still feels somewhat numb and he said he cannot make a fist with that hand. He also said he has
numbness on his neck. I informed Nurse
He stated the toilet in his cell was running for 45 minutes last night and he could not take the noise. He is going to try the
toilet before going to legal today and if it does not shut off, he will be moved to another cell.
Thanks,
7/28/2019 7:36 AM
Inmate
is being taken off of Psych Observation.
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Pending Bedspace for SHU
1,
Thank you,
CONFIDENTIAL
SDNY_00009794
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=== Page 1 ===
From: "Westlaw@westlaw.com" <Westlaw@westlaw.com>
To:
Subject: U.S. V. Neill
Date: Wed, 11 Apr 2018 12:16:12 +0000
Attachments: US_v_Neill.rtf
sent you content from Westlaw.
Please see the attached file.
Item: U.S. V. Neill
Citation: 952 F.Supp. 834
Sent On: Wednesday, April 11, 2018
Sent By:
Client ID: DOJ
Note:
Westlaw © 2018 Thomson Reuters. No claim to original U.S. Government Works.
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=== Page 1 ===
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
2.
(Forensic)
Thank you,
CONFIDENTIAL
SDNY_00009867
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=== Page 1 ===
Bureau of Prisons
Health Services
Clinical Encounter
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth:
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/23/2019 06:20
Provider: Joaquin, Y. MLP
Unit:
H01
Injury Assessment - Non-work related encounter performed at Health Services.
SUBJECTIVE:
INJURY 1
Provider: Joaquin, Y. MLP
Date of Injury:
07/23/2019 01:27
Date Reported for Treatment: 07/23/2019 08:25
Work Related:
No
Work Assignment: UNASSG
Pain Location:
Pain Scale: 0
Pain Qualities:
Where Did Injury Happen (Be specific as to location):
Special Housing Unit Z05-Cell 124 L
Cause of Injury (Inmate's Statement of how injury occurred):
"I do not know. Just went to drink a little water and wake up snorting".
Symptoms (as reported by inmate):
None
OBJECTIVE:
Temperature:
Date
Time
Fahrenheit
Celsius
Location
Provider
07/23/2019
06:30 NYM
97.5
36.4
Oral
Joaquin, Y. MLP
Pulse:
Date
Time
Rate Per Minute
Location
Rhythm
Provider
07/23/2019 06:30
92
Via Machine
Regular
Joaquin, Y. MLP
Respirations:
Date
Time
Rate Per Minute Provider
07/23/2019
06:30 NYM
16 Joaquin, Y. MLP
Blood Pressure:
Date
Time
Value
Location
Position
Cuff Size
Provider
07/23/2019
06:30 NYM
140/85
Right Arm
Sitting
Adult-regular Joaquin, Y. MLP
SaO2:
Date
Time
Value(%) Air
Provider
07/23/2019
06:30 NYM
96 Room Air
Joaquin, Y. MLP
Exam:
General
Affect
Yes: Cooperative
Appearance
Yes: Appears Well, Alert and Oriented X 3
No: Appears Distressed, Lethargic, Dyspneic, Appears in Pain, Pallor, Cyanotic, Diaphoretic, Disheveled,
Generated 07/23/2019 09:05 by Joaquin, Y. MLP
Bureau of Prisons - NYM
Page 1 of 2
CONFIDENTIAL
SDNY_00008777
EFTA00033588

=== Page 2 ===
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth:
Sex:
M Race: WHITE
Facility: NYM
Encounter Date: 07/23/2019 06:20
Provider: Joaquin, Y. MLP
Unit: H01
Exam:
Acutely III
Pulmonary
Auscultation
Yes: Clear to Auscultation, Vesicular Breath Sounds Bilaterally
No: Crackles, Rhonchi, Wheezing
Exam Comments
Inmate for injury report as requested by Operational Lt.
He is ambulatory, oriented X 3. In not apparent distress, smiling during this clinical encounter. Alleges, that he does not
know what happened. Can not explain the marks on his neck. Responded: "I don't know".
He does not want to talk of the events leading to the marks on his neck.
He does not look in any distress or pain.
Has an circular line of erythema at the base of the neck. Reaching 2/3 of the neck circumference, 2 inches wide, sparing
the back of the neck. Has one section of this erythema in the front with marks of friction.
No inflammation, no deformities, no hematomas, no lacerations, no tenderness. Patient moving his neck without any
restriction. Denies having any pain or discomfort. Denies any respiratory problem.
Has another small erythema on left knee about 2cm in diameter(mild).
As per information from custody staff inmate Epstein was found in his cell with a rope around his neck and sitting on the
floor.
Inmate is currently placed on suicide watch.
ASSESSMENT:
Injury, unspecified, T1490 Current - R/O self inflicted injuries.
PLAN:
Disposition:
Follow-up at Sick Call as Needed
Placed on Suicide Watch
Follow-up in 2-4 Hours
Other:
For follow up with psychology service.
Patient Education Topics:
Date Initiated Format
Handout/Topic
Provider
Outcome
07/23/2019 Counseling
Access to Care
Joaquin, Y.
Verbalizes
Understanding
07/23/2019 Counseling
Plan of Care
Joaquin, Y.
Verbalizes
Understanding
Copay Required: No
Cosign Required: Yes
Telephone/Verbal Order: No
Completed by Joaquin, Y. MLP on 07/23/2019 09:05
Requested to be cosigned by Beaudouin, Robert MD.
Cosign documentation will be displayed on the following page.
Generated 07/23/2019 09:05 by Joaquin, Y. MLP
Bureau of Prisons - NYM
Page 2 of 2
CONFIDENTIAL
SDNY_00008778
EFTA00033589


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=== Page 1 ===
From: Jenna Dabbs
To:
)"
Cc: Alex Conlon
Subject: Re: Epstein
Date: Sun, 11 Aug 2019 01:53:01 +0000
We appreciate the offer of support for
has been in touch with her several times today and, as you
might expect, she is experiencing a lot of different emotions. We will stay on top of it, I know she has already
been in touch with support folks at FBI, and will certainly circle up with you if need be.
Best,
Jenna
Get Outlook for iOS
From:
Sent: Saturday, August 10, 2019 7:18:59 PM
To: Jenna Dabbs
Cc: Alex Conlon
is
)
Subject: RE: Epstein
Jenna,
It was very shocking news, particularly given the entirety of the circumstances. And we appreciate the kind words,
particularly given your experience-that's very kind and it's meaningful to hear.
In terms of initial substantive questions, unfortunately I think we won't have robust answers quite yet-right now we
don't have any additional information on civil forfeiture in particular, and I also don't know what if any options there are
for us in terms of restitution (separate from the civil context). With respect to the investigation, we're not in a position to
talk about specific possible paths forward, but we can say, consistent with a brief statement our Office put out this
afternoon, that the investigation remains ongoing-and in the coming days we can talk with more particularity about
what that might mean for
in particular. In the meantime, though, in terms of
herself, we're continuing to
try to see if there are immediate options for resources in the next 24 hours, but even if we are not able to do so
tomorrow, certainly on Monday at the latest you and/or she can be in touch with our Office's specialists and/or the FBI
folks. We certainly want her to have any support that would be useful, and we are happy to stay in touch about that-
please let us know especially if you think her situation is, or becomes, an emergency.
Thank you again,
From: Jenna Dabbs
Sent: Saturday, August 10, 2019 09:50
To:
is
)
is
Cc: Alex Conlon
Subject: Epstein
We were certainly saddened to see the news this morning, as I know all of you were. I appreciate that you have more
EFTA00032290

=== Page 2 ===
pressing issues to deal with at the moment, but we are interested in whether you expect any aspect of the SDNY's
investigation/case to continue, potentially a separate civil forfeiture proceeding, or possible criminal prosecutions against
other defendants. We also understand that you may not be in a position to tell us anything at the moment, which is fine.
Just anticipating and preparing for questions we expect to be asked. Separately, having had the experience of a defendant
in a case I charged commit suicide, I wanted to add that it can be a complicated feeling, and to the extent it is helpful, I
think you brought a really important case and conducted yourselves in a professional, compassionate and impressive way.
So despite sad news, and frustrating news after putting so much work into filing a case and preparing to see it through,
heads should be held high.
Best,
Jenna
Jenna Dabbs I Kaplan Hecker & Fink LLP
35° Fifth Avenue Suite 7110
New York New York 10118
(W)
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00032291


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032620.pdf
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c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
)"
Subject: RE: Proposed Budget -- USA V. Maxwell
Date: Tue, 31 Aug 2021 00:35:57 +0000
Attachments: USA47_Request_form.pdf;_Lit_Consultant_SOW_(Taylor_Trial_Consulting).docx
Budget_Proposal_for_Jury_Consulting_Services_for.docx
Please see attached. I didn't fill out the TIN on the USA47 request form. Please let us know if you need anything further.
Thanks!
From:
(USANYS)
Sent: Thursday, August 26, 2021 11:26 AM
To:
is
(USANYS)
is
Subject: FW: Proposed Budget -- USA V. Maxwell
I found the vendor in UFMS. No need for the vendor form.
From:
(USANYS)
Sent: Thursday, August 26, 2021 11:14 AM
To:
is
V.
Subject: FW: Proposed Budget -- USA V. Maxwell
Hi -
Please complete the USA4 request form, SOW, and have the vendor complete the payment info form. Return to me to
process.
From:
(USANYS)
Sent: Thursday, August 26, 2021 11:03 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: FW: Proposed Budget -- USA V. Maxwell
We are going to go ahead with this litigation consultant. Please work with
and
on it.
Thanks,
EFTA00032620

=== Page 2 ===
From: Paulette Taylor
Sent: Wednesday, July 21, 2021 7:16 PM
To:
(USANYS)
Subject: Proposed Budget -- USA V. Maxwell
Here is the budget for the focus group, pretrial juror questionnaire, and feedback on the opening statement and closing
argument.
The proposal does not assume we would review and grade the completed juror questionnaires. As I noted in the
proposal, the cost is approximately $8,000 per 100 questionnaires as we can grade only 5 or 6 an hour. We have not
provided this service in recent cases, e.g., Silver and Skelos. However, we have provided it in earlier cases, e.g., Martha
Stewart, where we were also present in court during jury selection.
I am suggesting we hold the focus group on Friday, October 1, subject to consensus among the team. I can be available on
other dates as necessary.
Let me know what questions you have.
Paulette
Taylor'd Trial Consulting
Paulette Taylor, President
EFTA00032621


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=== Page 1 ===
From:
To:
Subject:
Epstein, Reg. No. 76318-054
Date:
Saturday, August 10, 2019 6:14:05 PM
Attachments:
TEXT.htm
2019 08 10 18 12 55 pdf
Psych Ops discontinued on 7/30/18 at 8:15 am
EFTA00032994


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c7: images
c0:
=== Page 1 ===
To:
Cc:
From:
Sent:
Mon 8/12/2019 7:14:35 PM
Subject: I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
TEXT.htm
2019 08 12 15 10 43.pdf
I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M
companion was utilized).
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
CONFIDENTIAL
SDNY_00009542
EFTA00033873


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=== Page 1 ===
UNITED STATESATTORNEYS
Request, Authorization, and Order for Services of
Expert Witness, Litigative Consultant, or ADR Neutral
Contract/Purchase Order No.:
Date:
Part I- Request for Services
1. Requesting Official (Name & Title)
2. Signature of Requesting Official
3. Point of Contact (Name and Tel.)
4. Date of Request
Telephone:
5. Preparer (Name & Tel.)
6. Originating Office (Name & Address)
7. Case Name, Court & Ct. Docket No.
8. DJ File No./USAO No.
9. Contractor (Name and Tel.)
10. Contractor Mailing Address
11. Contractor TIN or SSN (individual)
12. Contractor Specialty
Telephone:
13. Reason for Request (Place an "X" in the applicable Box in the Left Column)
13.a. Expert Testimony on Behalf of U.S.
13.b. Deposition Conducted by DOJ Attorney
13.c. Medical Examination of Plaintiff/Witness/Defendant in Contemplation of Testimony on Behalf of U.S.
13.d. Examination Under 18 USC 4241, Mental Competency to Stand Trial Only
13.e. Dual Purpose Psychiatric Examination (Time of Offense and Competency to Stand Trial) on the motion of:
13.f. ADR Neutral Services
13.g. Litigative Consultant Services
13.h. Other (explain below):
Attach the Statement of Work to this Form
14. Negotiated Contractor Rates, Estimated Expenses, and Performance Dates (Note: Expenses incurred must be supported by receipts)
Service/Expense
Performance Dates (From-To)
Hour/Day
Quantity
Rate
Total
14.a. Examine Case
-
Hour
$ 0.00
14.b. Prepare Testimony
-
Hour
$0.00
14.c. Court Testimony
-
Hour
$0.00
14.d. Deposition
-
Hour
$ 0.00
14.e. Litigative Consultant/Neutral
-
Hour
$ 0.00
14.f. Per Diem (if not part of fee)
Day
$ 0.00
14.g. Privately Owned Vehicle (NTE coach rate)
Mile
$ 0.00
14.h. Common Carrier Transportation Via GTA
14.i. Common Carrier Transportation Reimbursed
14.j. Miscellaneous
14.k. Total Estimated Expenses
$ 0.00
15. Submit Invoices & EFT Information to:
16. Payment will be made by: (Place an "X" in the applicable Box and fill-in if not JMD/Finance)
U.S. Attorney's Office, SDNY
X
Box 15
Budget & Fiscal Unit
or email:
Form USA-47 (Revised 5-2008)
Page 1 of 2
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=== Page 1 ===
To:
From:
Sent:
Tue 7/23/2019 12:32:11 PM
Subject:
Suicide Watch/Psych Observation Update
TEXT.htm
Suicide Watch
1. Epstein #76318-054
Psych Observation
None
Thank you,
CONFIDENTIAL
SDNY_00009872
EFTA00034019


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=== Page 1 ===
Event: t/c with Colleen re:
Start Date: 2020-08-21 20:00:00 +0000
End Date: 2020-08-21 20:30:00 +0000
Organizer:
)
Location:
Class: X-PERSONAL
Date Created: 2020-08-20 22:13:03 +0000
Date Modified: 2020-08-20 22:13:03 +0000
Priority: 5
DTSTAMP: 2020-08-20 22:09:09 +0000
Attendee:
)
is
i
(USANYS)
Alarm: Display the following message 15m before start
Reminder
I'm happy to handle this, but sending in case anyone else prefers to jump on as well.
EFTA00032233


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032594.pdf
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c0:
=== Page 1 ===
From: Sigrid McCawley
To:
(USANYS)"
Cc:
)"
)"
Subject: [EXTERNAL] Re: Rule 17(c) subpoena
Date: Thu, 18 Nov 2021 11:42:21 +0000
I am sorry I missed this email. I am available this morning if you want to speak.
Get Outlook for iOS
From:
(USANYS)
Sent: Wednesday, November 17, 2021 10:46:02 PM
To: Sigrid McCawley
Cc:
is
)
is
Subject: RE: Rule 17(c) subpoena
Hi Sigrid,
Do you have 5 minutes to chat tonight or early tomorrow morning?
Thanks!
From: Sigrid McCawley
Sent: Tuesday, November 16, 2021 5:51 PM
To:
(USANYS)
Cc:
>;
is
Subject: [EXTERNAL] Re: Rule 17(c) subpoena
Sounds good
Get Outlook for iOS
From:
(USANYS)
Sent: Tuesday, November 16, 2021 5:49:58 PM
To: Sigrid McCawley
Cc:
is
>;
Subject: RE: Rule 17(c) subpoena
Hi Sigrid - Sorry for the delay. I will call you in a few minutes if that still works for you.
From: Sigrid McCawley
Sent: Tuesday, November 16, 2021 5:37 PM
To:
(USANYS)
Cc:
is
V.
EFTA00032594

=== Page 2 ===
Subject: [EXTERNAL] RE: Rule 17(c) subpoena
Hi
- just checking in to see if you will be calling me or if there is a dial in? Or maybe you are still busy in court?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From:
(USANYS)
Sent: Monday, November 15, 2021 9:38 PM
To: Sigrid McCawley
Cc:
is
>;
Subject: Rule 17(c) subpoena
Hi Sigrid,
Attached is a motion that Maxwell's counsel filed seeking to subpoena information from the Epstein Victim Compensation
Fund, including information about
We intend to file a motion to quash the subpoena later this week. Happy to
have a call if you would like to discuss or have any questions.
Separately, can we find a time to talk tomorrow or Wednesday about scheduling? I'll be in court for jury selection, but I'm
free during the break from 1-2 p.m. EST or after 5 p.m. EST.
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:
(
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attomey work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attomey work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
EFTA00032595

=== Page 3 ===
the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00032596


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033691.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
To:
From:
Sent:
Mon 8/12/2019 7:35:44 PM
Subject: Re: Psych Observation 7/8/19 6 pm until 7/10/19 at 9 am re: Epstein, Jeffrey Edward, Reg.
No. 73618-054
TEXT.htm
When I try to open it says "document cannot be opened because it is corrupted or damaged"
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)" <cedge@bop.gov>
Date: 8/12/19 3:33 PM (GMT-05:00)
To:
Cc:
Subject: Psych Observation 7/8/19 6 pm until 7/10/19 at 9 am re: Epstein, Jeffrey Edward, Reg.
No. 73618-054
)" 08/12/2019 15:33 >>>
Psych Observation 7/8/19 6 pm until 7/10/19 at 9 am (I/M companion utilized)
CONFIDENTIAL
SDNY_00009121
EFTA00033691


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c7: images
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=== Page 1 ===
Psych Observation 7/24-30/19 (I/M companion utilized)
CONFIDENTIAL
SDNY_00009647
EFTA00033925


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032317.pdf
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c7: images
c0:
=== Page 1 ===
From:Access to Justice Law360 <news-alt@law360.com>
To:<
Subject:How Litigation Funding Can Save, And Doom, Poor Plaintiffs
Date:Mon, 13 May 2019 12:17:55 +0000
Law36
Access to Justice
0 Access
to
Justice
large
Monday, May 13, 2019
How Litigation Funding Can Save, And Doom, Poor Plaintiffs
LAW FIRMS
Adams and Reese
Companies that give cash advances on lawsuit settlements can help plaintiffs in
need, but few are watching this growing industry, leaving a vulnerable population
Akerman
at the mercy of largely unregulated lenders.
Akin Gump
Read full article
Allen Matkins
Alston & Bird
Archer & Greiner
Man Beats Murder Charge, And Odds, By Helming Own Case
Arent Fox
Eight years into what ultimately became a nearly 13-year prison stint, Hassan
Armstrong Teasdale
Bennett made the rare and often criticized choice to take over as his own
Arnall Golden
counsel as he fought charges for a murder he insisted he didn't commit. This
Arnold & Porter
month, however, he finally became a free man.
Read full article
Ashcraft & Gerel
Atkinson Andelson
Babst Calland
Can Online 'Pajama Courts' Reshape Justice?
Baker Botts
At any given hour of the day, someone in Utah could be wearing pajamas, sitting
Baker Donelson
in bed, sipping a coffee - and handling a legal dispute over a $500 debt.
Baker McKenzie
Read full article
BakerHostetler
Balch & Bingham
Ballard Spahr
Legal Aid Groups Think Bold To Fill Rural Gaps
Banner & Witcoff
Living in a vast state where wide swaths of land are unreachable by road, many
Barack Ferrazzano
Alaskans lack regular access to police, courts and the legal services that
concentrate in urban areas. To combat the problem, the Alaska Legal Services
Barasch McGarry
Corp. had to accept one fundamental fact.
Barclay Damon
Read full article
Barnes & Thornburg
Bass Berry
Becker & Poliakoff
Female Defenders Decry Handling Of 'Heinous' Sex Conduct
Benesch Friedlander
A lawsuit against Cook County, Illinois is forcing a discussion on how to protect
Bernstein Shur
female public defenders from sexual harassment when they visit clients in
Berry Appleman
EFTA00032317

=== Page 2 ===
courthouse detention facilities and jails.
Best Best & Krieger
Read full article
Beveridge & Diamond
Bingham Greenebaum
Blank Rome
Haggis Case Tests Boundaries Of NYC Gender Violence Law
Boies Schiller
An appellate case in New York involving rape allegations against movie director
Bond Schoeneck
Paul Haggis is serving as a showcase for a New York City law against gender-
Bose McKinney
motivated violence, which supporters of the accuser say covers a wider
spectrum of crimes than Haggis wants the court to believe.
Bowles Rice
Read full article
Bowman and Brooke
Bracewell
Bradley Arant
Mass. Justices Won't Force Probes For Juror Language Bias
Bressler Amery
Judges aren't required to probe potential jurors for bias against non-English
Bricker & Eckler
speakers in criminal cases where a defendant uses an interpreter, the
Briggs and Morgan
Massachusetts Supreme Court has ruled, though it urged judges to do so when
Brinks Gilson & Lione
asked.
Read full article
Brown & James
Brown Rudnick
Brownstein Hyatt
Getting Random With Harvard A2J Lab's Greiner
Bryan Cave
Jim Greiner, director of Harvard University's Access to Justice Lab, wants to
Buchanan Ingersoll
bring randomized controlled trials to the practice of law. He says the results
Buckley LLP
could change the delivery of legal services and help those unable to afford
Burke Williams
lawyers.
Burns & Levinson
Read full article
Burns White
Burr & Forman
Perspectives
Butler Snow LLP
Calif. Lawmakers Should Stay Out Of USC Sex Abuse Case
Butler Weihmuller
A pending settlement between the University of Southern California and 17,000
Butzel Long
former students would resolve claims over the actions of a sexually abusive
Cahill Gordon
gynecologist. But proposed state legislation could undermine the settlement,
Calfee Halter
says Shook Hardy partner Phil Goldberg, director of the Progressive Policy
Carlton Fields
Institute's Center for Civil Justice.
Carr Allison
Read full article
Chamberlain Hrdlicka
Chapman and Cutler
Chiesa Shahinian
Cipriani & Werner
Cipriani and Werner
Clark Hill
Cleary Gottlieb
Cohen & Grigsby
Cole Schotz
Cole Scott
Connell Foley
EFTA00032318

=== Page 3 ===
Conner & Winters
Conroy Simberg
Constangy Brooks
Cox Castle
Cozen O'Connor
Crowe & Dunlevy
Crowell & Moring
Crowley Fleck
Cullen & Dykman
Curtis Mallet-Prevost
DLA Piper
Davis & Gilbert
Davis Graham
Davis Polk
Davis Wright Tremaine
Day Pitney
Debevoise & Plimpton
Dechert
Dentons
Desai Law Firm PC
Dickie McCamey
Dickinson Wright
Dilworth Paxson
Dinsmore & Shohl
Dorsey & Whitney
Drew Eckl
Drinker Biddle
Duane Morris
Eckert Seamans
Edelson PC
Epstein Becker Green
Eversheds Sutherland
Farella Braun
Fennemore Craig
Fenwick & West
Fish & Richardson
Fisher Phillips
FisherBroyles
Foley & Lardner
Foley & Mansfield
Foley Hoag
FordHarrison
Foster Pepper
EFTA00032319

=== Page 4 ===
Foster Swift
Fox Rothschild
Fredrikson & Byron
Freeborn & Peters
Fried Frank
Frost Brown Todd
Galloway Johnson
Garvey Schubert
Gibson Dunn
Godfrey & Kahn
Goldberg Segalla
Goodwin
Gordon & Rees
Goulston & Storrs
Gray Plant Mooty
Gray Reed
GrayRobinson
Greenberg Traurig
Greensfelder Hemker
Greenspoon Marder
Gunster
Hahn Loeser
Hall Booth
Hall Estill
Hall Render
Halloran & Sage
Hanna, Brophy, MacLean,
McAleer & Jensen, LLP
Hanson Bridgett
Harness Dickey
Harris Beach
Harter Secrest
Hawkins Parnell
Haynes and Boone
Haynsworth Sinkler
HeplerBroom LLC
Herrick Feinstein
Heyl Royster
Hinckley Allen
Hinshaw & Culbertson
Hodgson Russ
Hogan Lovells
Holland & Hart
Holland & Knight
EFTA00032320

=== Page 5 ===
Howard & Howard
Hughes Hubbard
Hunton Andrews Kurth
Husch Blackwell
Ice Miller
Irell & Manella
Jackson Kelly
Jackson Lewis
Jackson Walker
Jaffe Raitt
Jeffer Mangels
Jenner & Block
Johnson & Bell
Johnson Trent
Jomarron Lopez
Jones Day
Jones Walker
K&L Gates
Kasowitz Benson
Katten Muchin
Katz Marshall
Kaufman Borgeest
Kaufman Dolowich
Kean Miller
Keating Muething
Kelley Drye
Kelley Kronenberg
Kelly Hart
Kilpatrick Townsend
King & Spalding
Kirkland & Ellis
Kirton McConkie
Knobbe Martens
Kramer Levin
Kutak Rock
Lane Powell
Latham & Watkins
Lathrop Gage
Laughlin Falbo
LeClairRyan
Lenczner Slaght
Lewis Brisbois
Lewis Rice
EFTA00032321

=== Page 6 ===
Lewis Roca
Linebarger Goggan
Liskow & Lewis
Litchfield Cavo
Littler Mendelson
Locke Lord
Loeb & Loeb
Lowenstein Sandler
Lozano Smith
Lucas Magazine
Lydecker Diaz
Manatt Phelps
Manning & Kass
Margolis Edelstein
Marshall Dennehey
Mayer Brown
Maynard Cooper
McAfee & Taft
McAngus Goudelock
McCalla Raymer
McCarter & English
McDonald Hopkins
McElroy Deutsch
McGlinchey Stafford
McGuireWoods
McKool Smith
McLane Middleton
McNees
Michael Best
Miles & Stockbridge
Miller & Martin
Miller Canfield
Miller Nash
Mitchell Silberberg
Mitchell Williams
Modus Law
MoloLamken LLP
Montgomery McCracken
Moore & Van Allen
Morgan & Morgan
Morgan Lewis
Morris Bart
Morris Manning
EFTA00032322

=== Page 7 ===
Morrison & Foerster
Morrison Cohen
Morrison Mahoney
Munger Tolles
Munsch Hardt
Neal Gerber
Nelson Mullins
Nexsen Pruet
Nixon Peabody
Norris McLaughlin
Norton Rose Fulbright
Nutter McClennen
Obermayer Rebmann
Offit Kurman
Ogletree Deakins
Orrick Herrington
Parker Poe
Parsons Behle
Patterson Belknap
Paul Hastings
Paul Weiss
Peckar & Abramson
Pepper Hamilton
Perkins Coie
Phelps Dunbar
Phillips Lytle
Pierce Atwood
Plunkett Cooney
Polsinelli
Porter Hedges
Porter Wright
Post & Schell
Poyner Spruill
Procopio Cory
Proskauer Rose
Pryor Cashman
Quarles & Brady
Quinn Emanuel
Quintairos Prieto
Rawle & Henderson
Reed Smith
Reinhart Boerner
Richards Layton
EFTA00032323

=== Page 8 ===
Riker Danzig
Rivkin Radler
Robbins Geller
Robins Kaplan
Robinson & Cole
Robinson Bradshaw
Roetzel & Andress
Ropers Majeski
Ropes & Gray
Rutan & Tucker
Sandberg Phoenix
Sanford Heisler
Saul Ewing
Schiff Hardin
Schnader Harrison
Schulte Roth
Schwabe Williamson
Schwegman Lundberg
Segal McCambridge
Seward & Kissel
Seyfarth Shaw
Shearman & Sterling
Sheppard Mullin
Sherman & Howard
Shipman & Goodwin
Shook Hardy
Shumaker Loop
Shutts & Bowen
Sidley Austin
Sills Cummis
Simmons Hanly
Simpson Thacher
Sirote & Permutt
Skadden
Smith Anderson
Smith Gambrell
SmithAmundsen LLC
Snell & Wilmer
Spencer Fane
Spilman Thomas
Squire Patton Boggs
Stearns Weaver
Steptoe & Johnson LLP
EFTA00032324

=== Page 9 ===
Steptoe & Johnson PLLC
Sterne Kessler
Stevens & Lee
Stinson Leonard
Stites & Harbison
Stoel Rives
Stoll Keenon
Stradley Ronon
Stradling Yocca
Strasburger & Price
Sullivan & Cromwell
Sullivan & Worcester
Susman Godfrey
Swanson Martin
Swift Currie
Taft Stettinius
Taylor English
Thompson & Knight
Thompson Coburn
Thompson Coe
Thompson Hine
Troutman Sanders
Tucker Ellis
Tyson & Mendes
Ulmer & Berne
Vedder Price
Venable LLP
Vernis & Bowling
Verrill Dana
Vinson & Elkins
Vorys Sater
Wachtell Lipton
Waller Lansden
Warner Norcross
Weber Gallagher
Weitz & Luxenberg
Wheeler Trigg
White & Case
White and Williams
Whiteford Taylor
Wiggin and Dana
Wilentz Goldman
Wiley Rein
EFTA00032325

=== Page 10 ===
Williams & Connolly
Williams Mullen
WilmerHale
Wilson Elser
Wilson Sonsini
Windels Marx
Winstead PC
Winston & Strawn
Winthrop & Weinstine
Wolf Greenfield
Womble Bond Dickinson
Wood Smith
Woods Oviatt
Wyatt Tarrant
Young Conaway
Zuckerman Spaeder
von Briesen
COMPANIES
Altman Weil Inc.
Ameren Corp.
American Bar Association
American Civil Liberties
Union
American Electric Power
Co. Inc.
Apple Inc.
BTI Consulting Group Inc.
BuzzFeed Inc.
DTE Energy Co.
Defender Association of
Philadelphia
Deloitte Touche
Deutsche Bank AG
Facebook
FirstEnergy Corp.
GlaxoSmithKline
Google Inc.
Huawei Technologies
International Association of
Privacy Professionals
Kirkland's, Inc.
Meritor Inc.
NFL Enterprises LLC
EFTA00032326

=== Page 11 ===
National Women's Law
Center
New York Times Co.
New York Yankees
Pew Charitable Trusts
Pinterest Inc.
Platinum Partners LP
Sephora SA
Spotify Technology SA
T-Mobile USA Inc.
The Southern Company
Inc.
UnitedLex Corp.
Verizon Communications
Inc.
Vistra Energy Corp.
ZTE Corp.
GOVERNMENT
AGENCIES
California Supreme Court
Consumer Financial
Protection Bureau
Federal Reserve System
Federal Trade Commission
Legal Services Corp.
New York Attorney
General's Office
Office of Foreign Assets
Control
Ontario Securities
Commission
Securities and Exchange
Commission
Social Security
Administration
Tennessee Valley Authority
U.S. Attorney's Office
U.S. Department of Justice
U.S. Environmental
Protection Agency
U.S. House Committee on
Energy and Commerce
U.S. Supreme Court
EFTA00032327

=== Page 12 ===
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EFTA00032328


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=== Page 1 ===
Lieutenant's log and daily activities report for Sunday, July 21, 2019.
Lieutenant
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, N.Y. 10007
CONFIDENTIAL
SDNY_00008767
EFTA00033586


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=== Page 1 ===
From:
"
)"
To: "
Cc:
"
(USANYS)"
)"
Subject: Letter/suppression issue
Date: Wed, 21 Apr 2021 15:00:19 +0000
Attachments: 2021-04-21_Gov't_response_to_April_19_Order.docx
H
Attached is the rough draft of the letter - thanks so much for your guidance on this. If you happen to have any
edits/comments, that would be much appreciated. We're filing it at 5 today.
Thanks,
EFTA00032771


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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Monday, July 29, 2019
Beginning Count: 766
SHU: 73/5
Daily Sensitive Information:
I/M Melendez #85799-054 at Local Hosp. USMS Guards
M/W
I/M Lans #86357-054 at local hosp. w/inst. staff
I/M Epstein #76318-054 on Psych Obs. w/inmate companion
I/M
#20472-038 on Psych Obs. W/inmate companion.
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
766
73/5
Operations Lieutenant. The fire alarm and sprinkler system are
nonoperational, Fire Watch in progress. PREA announcement
conducted via the Institution Public Address System and/or Radio.
Restraint Equipment Cage inventory conducted. All equipment
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate/Facilities/R&D. Roof Check
completed. All secure. Temporary Chit Inventory: #1:2; #2:5;
#3:5; #4:6; #5:5; #6:0; Hosp:0
12:00
Institution Count in progress
AM
12:00
NYPD Phone Check #3832
AM
12:02
Body Alarm testing in progress
AM
12:11
Body Alarm testing completed
AM
12:30
Watch Calls/Fire Watch cont.
AM
12:30
Good Verbal count announced
AM
12:42
Clear Institution count announced
766
73/5
AM
3:00 AM
Institution Count in progress
3:33 AM
Good Verbal count announced
3:35 AM
Clear Institution count announced
766
73/5
5:00 AM
Institution Count in progress
5:31 AM
Good Verbal count announced
5:28 AM
Clear Institution count announced
766
73/5
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
766
73/5
STG International Terrorist phone calls monitored:
WITSEC inquiry was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 766 SHU: 73; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 03; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00
CONFIDENTIAL
SDNY_00009025
EFTA00033647

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: D/W Sunday, July 28, 2019
Beginning Count: 766
SHU: 73/5
D/W
Daily Sensitive Information:
I/M I/M Melendez #85799-054 at Local Hosp w/USMS Guards.
I/M Epstein on Psych obs. w/inmate companion
I/M
#20472-038 on Psych Obs. W/inmate companion.
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
766
73/5
Lieutenant. The fire alarm and pump system is inoperable at this
time. Fire Watch is in Progress. Unable to conduct PREA
announcement over the Institution Public Address System, due to,
system malfunction. Restraint Equipment Cage inventory conducted.
All equipment accounted for. Metal Detector checks conducted.
All operative w/the exception of Rear Gate. Roof Check
completed. All secure. Temporary Chit Inventory: #1:0; #2:5;
#3:5; #4:6; #5:6; #6:5; Hosp:0
Daily Hand Stamp :GPKJ / LEFT HAND
8:00 AM
NYPD Phone Check #.2522
8:25 AM
Body Alarm Test Initiated.
8:30 AM
AM Census count
9:01 AM
Body Alarm Testing Complete.
9:06 AM
-1 L-HOSP: Gil-Cabral #86292-054
765
73/5
10:00 AM
Institution count.
10:20 AM
Good verbal announced.
10:42 AM
Clear count announced.
11:00 AM
Mainline feeding in progress.
12:02 PM
+1 L-HOSP return: Gil-Cabral #86292-054
766
73/5
12:30 PM
PM Census count
2:43 PM
I/M Smith #78175-054 escorted to the Special housing Unit.
766
74/5
3:02 PM
I/M Lans #86357-054 return from local hospital with Bop staff.
767
75/5
3:25 PM
Three inmates released from ZA to general population: Martin
767
72/5
#86887-054, Tabar #79662-054, Williams #86162-054.
3;40 PM
I/m Lopez #20472-038 released from HA to KN
3:45 PM
Institutional lockdown for count.
4:00 PM
Relieved of duties by Lt.
as E/W Operations Lieutenant.
767
72/5
Visitation: NA
Inmates
Adults
Children
Total
N/A
N/A
N/A
N/A
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored: 9
CONFIDENTIAL
SDNY_00009026
EFTA00033648

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Ops Lt
Ending Count: 767 ; SHU: 72; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
CONFIDENTIAL
SDNY_00009027
EFTA00033649

=== Page 4 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHU: 72/
SHIFT-DAY-DATE: E/W Monday, July 29, 2019
Beginning Count: 767
5
Daily Sensitive Information.
E/W
I/M Burnett #76254-054 at Goldcrest nursing facility w/USMS Guards
I/M Melendez #85799-054 at Brooklyn Hospital w/USMS Guards
I/M Epstein #76318-054 on Suicide Watch. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch Operations
Lieutenant. Unable to conduct PREA announcement over the
Institution Public Address System, due to, system malfunction.
4:00 PM
Restraint Equipment Cage inventory conducted. All equipment
767
72/5
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:01 PM
NYPD Phone Check #9142
4:07 PM
Body Alarm testing in progress.
4:26 PM
Body alarm testing completed.
5:11 PM
Good verbal announced.
5:28 PM
Clear institutional count.
767
72/5
5:29 PM
Inmate Wilson #69068-054 removed from GN to ZA
73/5
5:30 PM
Inmate Jaquez #79306-054 removed from GN to ZA
74/5
5:46 PM
-1 Bail/Bond: Shokralla #76323-054
766
6:00 PM
Watch call in progress
6:46 PM
+2 New commit: Chairez #76325-054, Clark #53358-054
768
74/5
6:58 PM
-1 GCT REL: Castillo #77281-054,
767
74/5
7:13 PM
3 I/M released from ZA to general population: Grananos #76161-
767
71/5
2054, Mobley #85605-054, Espinal #86918-054
8:09 PM
Trash run in progress
8:30 PM
Trash run complete
10:00
Institutional count in progress.
PM
10:34
Good verbal count announced.
PM
10:38
Clear institutional count announced.
767
71/5
PM
12:00
Relieved of duties by Lt.
as the M/W Lieutenant.
767
71/5
AM
VISITING: UNIT 2
INMATES
ADULTS
CHILDREN
TOTAL
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
Wilson
69068-054
108,218,307
GN
5:29 PM
YES
CONFIDENTIAL
SDNY_00009028
EFTA00033650

=== Page 5 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Jaquez
79306-054
307
GN
5:30 PM
YES
Ops. Lt.
Ending Count: 767 ; SHU: 71; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 02; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
CONFIDENTIAL
SDNY_00009029
EFTA00033651


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=== Page 1 ===
From: Jean James <jeanjames@telus.net>
To: geoffrey berman
Subject: BRITISH FREEDOM OF INFORMATION REQUEST RE EPSTEIN & PARLIAMENT
Date: Tue, 03 Sep 2019 15:13:36 +0000
Importance: Normal
https://www.whatdotheyknow.com/request/emails_leaked_to_the_daily_mail
EFTA00032299


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10643456 approved by
, now awaiting further
approval
Date: Fri, 13 Sep 2019 01:46:08 +0000
Importance: Normal
Dear
Travel authorization 10643456 has been approved by
, now awaiting further approval.
Trip ID: 10643456
Traveler nam
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Los Angeles, CA, United States
Dates: 2019-09-17 - 2019-09-20
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
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Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
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Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00032629


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
)"
(USANYS)"
Subject: OPR and PMRU Stuff
Date: Thu, 08 Apr 2021 17:22:47 +0000
Here's the relevant section of the Epstein OPR report, and the Justice Manual provision on the Professional
Misconduct Review Unit, to which OPR findings of professional misconduct get referred.
From the public Epstein OPR Executive Summary (fn's omitted):
III. OVERVIEW OF OPR'S ANALYTICAL FRAMEWORK
OPR's primary mission is to ensure that Department attorneys perform their duties in accordance with the
highest professional standards, as would be expected of the nation's principal law enforcement agency.
Accordingly, OPR investigates allegations of professional misconduct against current or former Department
attorneys related to the exercise of their authority to investigate, litigate, or provide legal advice. OPR also has
jurisdiction to investigate allegations of misconduct against Department law enforcement agents when they relate
to a Department attorney's alleged professional misconduct.
In its investigations, OPR determines whether a clear and unambiguous standard governs the challenged conduct
and whether a subject attorney violated that standard. Department attorneys are subject to various legal
obligations and professional standards in the performance of their duties, including the Constitution, statutes,
standards of conduct imposed by attorney licensing authorities, and Department regulations and policies. OPR
finds misconduct when it concludes by a preponderance of the evidence that a subject attorney violated such a
standard intentionally or recklessly. Pursuant to OPR's analytical framework, when OPR concludes that (1) no
clear and unambiguous standard governs the conduct in question or (2) the subject did not intentionally or
recklessly violate the standard that governs the conduct, then it concludes that the subject's conduct does not
constitute professional misconduct. In some cases, OPR may conclude that a subject attorney's conduct does not
satisfy the elements necessary for a professional misconduct finding, but that the circumstances warrant another
finding. In such cases, OPR may conclude that a subject attorney exercised poor judgment, made a mistake, or
otherwise acted inappropriately under the circumstances. OPR may also determine that the subject attorney's
conduct was appropriate under the circumstances.
From the Justice Manual
1-4.320 - Adjudicating Findings of Attorney Professional Misconduct-The
Professional Misconduct Review Unit
Mission. Where OPR has made findings of attorney professional misconduct, those findings are referred to the
Department's Professional Misconduct Review Unit (PMRU). Consistent with memoranda issued separately by the Deputy
Attorney General, the PMRU evaluates any findings of professional misconduct by OPR and, where appropriate, issues fair,
timely, and consistent disciplinary decisions. The PMRU also authorizes referrals to the appropriate bar authority in those
instances in which OPR concludes that a current or former Department attorney violated a rule of professional conduct
during his or her tenure with the Department.
Authority of the PMRU. The PMRU has authority to handle disciplinary matters involving career Department attorneys,
except for those employed in the law enforcement components and certain employees of the Executive Office for
Immigration Review. The PMRU has no authority to adjudicate disciplinary actions in misconduct cases pertaining to non-
career attorneys (whether appointed by the President with Senate confirmation, or otherwise politically appointed). The
PMRU Chief has authority in his or her discretion to choose not to sustain findings of misconduct referred to the PMRU.
The PMRU Chief also has the authority in his or her discretion to include in the PMRU disciplinary decision any poor
judgment findings in reports of investigation that are closely related to the professional misconduct findings referred to the
PMRU. Closely related findings are those findings that arise from the same report of investigation, are made against the
same individual, and are based on the same or substantially similar conduct. The PMRU Chief's disciplinary authority
EFTA00032930

=== Page 2 ===
includes the authority to resolve or authorize the resolution of any disciplinary action pending before the PMRU without
the PMRU reaching a final decision on the merits of the action. Depending on the circumstances, the PMRU Chief may
serve as the Grievance Official to a Letter of Reprimand issued by a PMRU Attorney or the Deciding Official on a
suspension or removal action proposed by a PMRU Attorney. In all of its actions, the PMRU will operate in accordance
with the due process requirements established in 5 U.S.C. § 7500 et seq., and 5 C.F.R. Part 752.
Bar Referrals. At the conclusion of any final disciplinary action by the PMRU, including any decision from a final
appellate authority, if there is a final determination that a subject attorney committed professional misconduct implicating
a rule of professional conduct or when the PMRU Chief otherwise determines that a rule of professional conduct so
requires, the PMRU Chief will direct OPR to refer the subject attorney to the appropriate bar authority or authorities. For
former Department attorneys, the PMRU Chief may, after receiving an OPR report of investigation finding misconduct,
issue a letter advising the subject attorney of the misconduct findings and informing the subject attorney of the right to
submit an objection to OPR's findings. After receipt of an objection, if any, the PMRU Chief will determine if the matter
will be referred to the appropriate bar authority under the same procedures as for Department attorneys.
The Authority of the Deputy Attorney General. The Deputy Attorney General reserves the authority to designate
individuals outside of the PMRU to serve as proposing, deciding, or grievance officials in all disciplinary matters, including
those involving findings of professional misconduct by OPR, or to personally serve as the proposing, deciding, or grievance
official. The Deputy Attorney General also reserves the right to designate an acting PMRU Chief.
[updated September 2018]
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00032931


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=== Page 1 ===
From: Bruce Barket <bbarket@barketepstein.com>
To:
Cc: Aida Leisenring <aleisenring@barketepstein.com>
Subject: RE: Quarantine
Date: Tue, 01 Sep 2020 20:52:21 +0000
I just learned that he was being ordered onto another tier, where he does not believe he is safe. Worse, he was told that if
does not enter the tier where he believes he is in danger he will be sent to SHU. This is deeply troubling. MCC has kept
Mr. Tartaglione in quarantine for more than twice as long as he was supposed to be there and is now giving him the
Hobson's choice of SHU or risking his safety. And, his most of his property is still in the old cell where you assured us he
would be returned.
I am again asking that he be placed on a safe tier, in a safe cell with a cellmate who does not pose a threat to him,
preferably the cell where he has been detained for well over a year.
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
From:
Sent: Tuesday, September 1, 2020 1:35 PM
To: Bruce Barket <<barket@barketepstein.com>;
is
Cc: Aida Leisenring <aleisenring@barketepstein.com>
Subject: Re: Quarantine
Good afternoon-
It is my understanding that he is not in quarantine.
>>> Bruce Barket <bbarket@barketepstein.com> 9/1/2020 7:25 AM >>>
Good morning,
I understand that Mr. Tartaglione is still in quarantine although he was cleared to return to general population. As I wrote
over the weekend, apparently the MCC refused to place Mr. Tartaglione back in his cell where he has been safe or in a unit
of people over few years old. He is a retired police officer. As such he has been and is targeted for violence by other
inmates. Prior to being housed with his current cellmate, Mr. Tartaglione was assaulted resulting in surgery and an
extended stay in a hospital. For coming up on two years he has lived in a cell with a cellmate and has been relatively safe.
He was removed-supposedly for 14 days-over a month ago from that cell and is now being forced to either stay in
EFTA00032123

=== Page 2 ===
quarantine or be placed in a cell with a new cellmate where he may not be safe. We understood from you that he would
be returned to the cell where he has lived in relative safety after quarantine.
Can you please take the steps necessary to make sure Mr. Tartaglione is released from quarantine and placed in a cell that
is safe? 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
EFTA00032124


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
)"
Subject: 17(c) letter
Date: Thu, 18 Nov 2021 04:57:14 +0000
Attachments: 2021.11.18_Mot_to_quash.pdf; 2021.11.18_Mot_to_quash.docx
Hi all,
17(c) letter attached. If nobody has a minute to skim or read this between now and voir dire-which is my guess, given
the timing-I'll just send to
at 8:30.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00032593


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=== Page 1 ===
From: Nicole Simmons <nsimmons@hmflaw.com>
To: "NathanNYSDChambers@nysd.uscourts.gov"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, Laura Menninger <Imenninger@hmflaw.com>,
Ann Lundberg <alundberg@hmflaw.com>, "CEverdell@CohenGresser.com"
<CEverdell@CohenGresser.com>, "mcohen@CohenGresser.com"
<mcohen@CohenGresser.com>
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Request to Modify Protective Order
(Under Seal)]
Date: Tue, 18 Aug 2020 00:01:23 +0000
Attachments: 2020.08.17 JSP Ltr. Modification of the_Protective_Order.pdf;
2020.08.17_JSP_Rule_16.1_Affidavitpdf;Ex._1.pdf_Ex_2.pdf;Ex._3.pdf;_Ex_4.pdf
Ex._5.pdf; Ex_6.pdf,Ex_7.pdf Ex._8.pdf;Ex_9.pdf;,Ex._10.pdf
Inline-Images: image001.jpg
Dear Judge Nathan,
At the request of Jeffrey S. Pagliuca, please see attached Ms. Maxwell's Letter Motion, Affidavit, and accompanying
exhibits filed under seal today August 17, 2020.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
80203
PH 303.831.7364 FX
303.832.2628
DIRECT: 720.287.5835
www.hmflaw.com
nsimmons@hmflaw.com
EFTA00032234


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=== Page 1 ===
Event: Accepted: Meet re Epstein forfeiture
Start Date: 2019-12-09 19:00:00 +0000
End Date: 2019-12-09 20:00:00 +0000
Location: AA office
Class: X-PERSONAL
Comment:
Date Created: 2019-12-05 00:43:03 +0000
Date Modified: 2019-12-05 00:43:03 +0000
Priority: 5
DTSTAMP: 2019-12-04 19:18:25 +0000
Attendee:
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Discovery questions
Date: Wed, 19 Aug 2020 22:34:33 +0000
Yep, it looks like we have all of the trash pulls-I think they did the organizational structure you asked for when they gave
it to us back in September.
From:
Sent: Wednesday, August 19, 2020 2:33 PM
To:
)
Subject: FW: Discovery questions
For the scans, let me know if you're seeing things like trash pulls in the scans they sent you. It should be more than just
phone message pads. If it's not in there, let's take
up on the offer to request another copy from them.
From:
(NY) (FBI)
Sent: Wednesday, August 19, 2020 2:21 PM
To:
)
is
>;
)
Cc:
is
(USANYS)
Subject: RE: Discovery questions
Hey all, below is a summary of the discovery items you've requested.
Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page
without the post it note, so the pages are back to back.
Papers from Miami case file (grand jury testimony): This is a disk - I can copy it and send it over to you.
Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scans
last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from the
NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.
FBI file: We have that ready for you.
CART: There are no 302s regarding the extraction of devices.
Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This is
the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together, that
would be very helpful.
If it's helpful to talk through some of this via phone, we are happy to do that as well.
FBI New York Field Office
Child Exploitation/Human Trafficking
C: 917-692-0853
EFTA00032205

=== Page 2 ===
From:
Sent: Tuesday, August 18, 2020 6:41 PM
To:
Cc:
(NY) (FBI)
is
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thanks so much,
Really appreciate all the work you and
are putting in on this. Let's touch base tomorrow to
figure out the timeline for the discovery issues.
From:
Sent: Tuesday, August 18, 2020 6:40 PM
To:
is
Cc:
(NY) (FBI)
is
>;
(USANYS)
Subject: Re: Discovery questions
Hey guys,
Apologies but today I was out In the field on surveillance and
was also out of the office so we've not
been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into
this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to
get on this list. That being said I don't want to make you any promises that everything will be compiled by
tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you
like to square some of this away.
I did receive your "pages from Miami_case_docs" PDF.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Tuesday, August 18, 2020 6:03 PM
To:
is
Cc:
(NY) (FBI)
is
EFTA00032206

=== Page 3 ===
is
(USANYS)
Subject: RE: Discovery questions
Hi
and
Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these
materials tomorrow or Thursday?
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:41 PM
To:
is
Cc:
(NY) (FBI)
is
>;
(USANYS)
Subject: RE: Discovery questions
Hi
and
The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a
larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to
provide us with all of those scans this week?
With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on
them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:45 AM
To:
Cc:
(NY) (FBI)
is
)
>;
is
(USANYS)
Subject: RE: Discovery questions
Sorry, got a bounceback for
too. I'm just attaching the one page I referenced in my email below. Hopefully that
will go through.
From:
Sent: Tuesday, August 18, 2020 4:40 AM
To:
Cc:
(NY) (FBI)
i
V.
is
(USANYS)
Subject: FW: Discovery questions
I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went
through for
so she can see it. If not, please let me know.
EFTA00032207

=== Page 4 ===
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:33 AM
To:
is
(NY) (FBI)
Cc:
is
V.
(USANYS)
Subject: Discovery questions
Hi
and
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent
batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery
dropped off a few days ago with requests for additional items:
The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think
mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-and those
copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad
scans" folder. Would you please get us a scans of these without post-its on them?
It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would
you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
Full FBI sentinel file
CART paperwork regarding the extraction of data from all devices seized during the investigation
All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard
copy) seized during the investigation, including from Epstein's properties.
Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned,
including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or
partially nude images. For nude or partially nude images, please provide us with a log detailing how many such
images were scanned, where they were from, and where they are being stored.
Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform
for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images.
For nude or partially nude images, please provide us with a log detailing how many such images were located,
where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
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=== Page 1 ===
From: Securities Law360 <news@law360.com>
To:
Subject: Citing COVID-19, SEC Eases More Filing Requirements
Date: Mon, 30 Mar 2020 07:19:42 +0000
Law360
Securities
SECURITIES
Monday, March 30, 2020
Follow Securities Law360
TOP NEWS
Law360 Practice Groups of the
Citing COVID-19, SEC Eases More Filing Requirements
Year
The U.S. Securities and Exchange Commission has further extended its
guidance and relief to companies grappling with the fallout from the spread of
the novel coronavirus, temporarily easing certain compliance requirements
for corporations, municipal advisers and crowdfunded groups.
Read full article
YRC Slips Investor Suit Alleging It Overcharged DOD
YRC Worldwide escaped a proposed securities class action Friday after a
New York federal judge found that the freight shipping company had no duty
to disclose the government investigation that culminated in a civil suit over its
allegedly fraudulent overbilling.
Order attached Read full article
New Cases
Intercept Beats Investor Suit Over Liver Disease Drug Deaths
Intercept Pharmaceuticals Inc. on Thursday exited a proposed securities
Securities (6)
class action accusing it of covering up reports of fatalities and injuries caused
by a liver disease drug, after a New York federal judge found the
LAW FIRMS
shareholders failed to prove the existence of those reports was "material."
Abrams & Bayliss
Order attached Read full article
Adams & Reese
Andrews & Springer
NY Justices Take Up JP Morgan's $140M Coverage Battle
Arias Sanguinetti
New York's highest court on Thursday agreed to review a lower court's ruling
Austin LLP
that J.P. Morgan Securities Inc. is not entitled to insurance coverage for a
Barnes & Thornburg
$140 million chunk of a settlement that Bear Stearns paid to the U.S.
Securities and Exchange Commission because that sum is an uninsurable
Beatty & Wozniak
penalty.
Boies Schiller
Order List attached Read full article
Bond Schoeneck
Clyde & Co
Coronavirus Litigation: The Week In Review
Covington & Burling
Multiple public officials have been hit with lawsuits over their actions
Debevoise & Plimpton
surrounding the COVID-19 pandemic, vendors are facing allegations of price-
gouging, and a proposed class has accused China of hiding the dangers of
Dickinson Wright
the coronavirus outbreak and costing U.S. small businesses billions of
Dorsey & Whitney
dollars.
Duane Morris
Read full article
Epstein Becker Green
Faruqi & Faruqi
POLICY & REGULATION
Fish & Richardson
Fried Frank
Bank Regulators Unveil 2-Year Delay For CECL Adopters
EFTA00032901

=== Page 2 ===
Federal regulators said Friday that big banks can wait longer before phasing
Friedman Oster
in the regulatory capital effects of a new loan loss accounting standard and
Gallagher & Associates Law Firm
can choose to switch over early to an updated methodology for calculating
Gallo Vitucci
certain capital requirements, moves intended to buoy bank lending during the
COVID-19 pandemic.
Gibson Dunn
2 documents attached Read full article
Glancy Prongay
CIVIL ENFORCEMENT
Goodwin
Grabar Law
SEC Wins $417K In Fraud Suit Over Fracking Investments
Harrity & Harrity
The U.S. Securities and Exchange Commission won final judgment and more
Hill Ward Henderson
than $417,000 in disgorgement and fines in Georgia federal court Friday in its
Hogan Lovells
suit alleging a Kentucky roofer bilked fracking investors out of $15 million in a
securities fraud scheme.
Husch Blackwell
Order attached Read full article
Jenner & Block
Jones Day
SEC Fines Texas Man $10K For Talking Up Penniless Funds
K&L Gates
The U.S. Securities and Exchange Commission filed and settled a civil
Kaplan Fox
complaint Thursday against a Texas man for allegedly lying to potential
Kaufman Borgeest
investors about two investment funds that never actually raised or invested
Kelley Kronenberg
any money.
2 documents attached Read full article
King & Spalding
Kirkland & Ellis
WHITE COLLAR
Klausner Kaufman
Labaton Sucharow
Ex-BigLaw Atty Can't Use Pandemic To Skirt Jail, Feds Say
Landman Corsi
Federal prosecutors said Friday that a former Locke Lord LLP attorney
Latham & Watkins
convicted of assisting a $400 million cryptocurrency scam can't use the
Locke Lord
COVID-19 crisis or any other excuse to be let out of jail before his
sentencing.
Lowey Dannenberg
Letter attached Read full article
Mayer Brown
Miller Canfield
DELAWARE
Miller Friel
Morgan Lewis
Murex Co-Founder, Ex-Wife See Most Record Demands Denied
Morris James
A co-founder of oil and gas venture Murex Petroleum and his ex-wife lost
Norton Rose
most of their bid for company records on Friday, after a Delaware vice
Pomerantz LLP
chancellor found many of their separate demands ineligible, improper or
sufficiently answered.
Proskauer Rose
Read full article
Reed Smith
Richards Layton
Brookfield Seeks Chancery Stay Or Toss Of Terraform Claims
Robbins Geller
Brookfield Asset Management asked Delaware's Chancery Court Thursday to
Robins Kaplan
stay a derivative suit and dismiss accompanying direct claims challenging a
Rosen Law Firm PA
$650 million private placement that boosted Brookfield's control of Terraform
Power in 2018, saying a pending buy-up of remaining Terraform shares
Saenz & Anderson
should soon end the class' derivative standing.
Sedgwick LLP
Read full article
Selendy & Gay
Sidley Austin
INVESTOR ACTIONS
Skadden
User Says Robinhood Is Trying To 'Wipe Out' Class Claims
Tarter Krinsky
A Robinhood customer moved for a temporary restraining order in one of
Wachtell Lipton
several class actions filed against the online trading app after users
Weil Gotshal
experienced significant issues with account access across two trading days,
Weitz & Luxenberg
saying the company has sought to "wipe out" the class' claims with a $75
Wilson Sonsini
credit contingent on signing a release.
Zimmerman Reed
2 documents attached
Read full article
COMPANIES
EFTA00032902

=== Page 3 ===
Window Co. Investors' Suit Dismissed For Lacking Clarity
Altman Weil Inc.
Glass and window manufacturer Apogee Enterprises Inc. has escaped a
Amazon.com Inc.
proposed securities class action after a Minnesota federal court judge found
American Bar Association
that the facts pled in the suit show that Apogee and its executives shared
adverse information as they discovered them, rather than hiding them, and
American International Group Inc.
that the suit lacked specifics.
Apogee Enterprises Inc.
Order attached Read full article
Apple Inc.
Berkeley Research Group
Sterling Bank Hid Risk, Tanking Stock, Investors Say
Brigham Young University
A group of peeved investors hit Sterling Bancorp Inc. with a proposed class
Brookfield Asset Management Inc.
action in Michigan federal court Friday, claiming its Michigan-based
Bryn Mawr Bank Corporation
subsidiary Sterling Bank and Trust FSB misled investors and ignited a stock
drop that resulted in massive damages to their holdings.
DocuSign Inc.
Complaint attached Read full article
Dole Food Company Inc.
Frito-Lay Inc.
EXPERT ANALYSIS
Intercept Pharmaceuticals Inc.
Intercontinental Exchange Inc.
COVID-19 Crisis Exposes Libor Replacement's Weaknesses
JPMorgan Chase & Co.
Fundamental differences in the way Libor and its pending replacement, the
Liberty Mutual Insurance Group
Secured Overnight Financing Rate, have tracked financial risk amid the
Linkedln Corp.
COVID-19 crisis suggest the transition between the two benchmarks will be
challenging, says Jeffrey Armstrong at the Berkeley Research Group.
Major Lindsey & Africa
Read full article
McDonald's Corp.
NASDAQ Inc.
Delaware Dole Ruling Will Guide Allocation In D&O Policies
Northwestern Memorial HealthCare
In a dispute between Dole Food and certain excess insurers of a directors
PepsiCo Inc.
and officers insurance policy, the Delaware Supreme Court recently
Planned Parenthood Federation
interpreted an explicit allocation provision and articulated a rule that will
instruct both insurers and insureds, say Brian Scarbrough and Huiyi Chen at
Porsche
Jenner & Block.
Robinhood Markets Inc.
Read full article
SIFMA
SolarCity Corp.
A Guide To Zealously Representing Clients During COVID-19
Spotify Technology SA
The American Bar Association's Model Rules of Professional Conduct require
lawyers to be zealous advocates for clients' interests, but how do these rules
Sterling Bancorp
apply in this unprecedented time of COVID-19? Anne Lockner at Robins
Sterling Bank & Trust
Kaplan offers some pointers.
Sterling Financial Corp.
Read full article
SunEdison LLC
Tesla Inc.
LEGAL INDUSTRY
The Brattle Group Inc.
The Hartford Financial Services
Firms Plan On Summer Associates Despite Virus Uncertainty
Group Inc.
Amid the disruption caused by the COVID-19 pandemic, Boies Schiller
The Travelers Companies Inc.
Flexner LLP, Covington & Burling LLP and Fried Frank Harris Shriver &
Twitter Inc.
Jacobson LLP all say they plan to continue with their summer associate
programs, though many of the law students hired for the programs might
Visa Inc.
wind up working remotely.
Wal-Mart Stores Inc.
Read full article
Wyndham Hotels and Resorts Inc.
YRC Worldwide Inc.
How Firms In Michigan Are Handling A Statewide Lockdown
Zeughauser Group LLC
Michigan is one of a handful of states that have now issued statewide
executive orders requiring residents to stay at home amid the novel
GOVERNMENT AGENCIES
coronavirus pandemic. Here, large law firms with offices in the state share
how they made the transition to a remote workforce and how they're coping.
Bank of England
Read full article
Delaware Court of Chancery
Federal Bureau of Prisons
Analysis
Federal Deposit Insurance Corp.
Agile But Vulnerable, Smaller Firms Fight To Weather Virus
Federal Reserve Bank of New York
EFTA00032903

=== Page 4 ===
Many midsize and smaller law firms have an edge over BigLaw when it
Federal Reserve Bank of St. Louis
comes to transitioning to remote work, but the longer-term potential impact
Federal Reserve System
on business development is weighing heavily on them.
Food and Drug Administration
Read full article
Analysis
Illinois Gaming Board
The Attys And Legal Logic Behind Stay-At-Home Orders
Occupational Safety and Health
The attorneys helping draft cities' and states' stay-at-home orders during the
Administration
coronavirus pandemic have been tiptoeing through a legal minefield, working
Office of the Comptroller of the
long hours to carve out the kind of work that should be considered "essential"
Currency
and to ensure local governments aren't overstepping their authority.
Securities and Exchange
Read full article
Commission
U.S. Attorney's Office
Q&A
Coping With A Pandemic: Fish & Richardson's Betsy Flanagan
U.S. Department of Defense
As self-isolation and social distancing become the norm during the COVID-19
U.S. Department of Homeland
pandemic, Law360 is sharing reactions from people around the business and
Security
legal community. Today's perspective comes from Betsy Flanagan, a Twin
U.S. Department of Justice
Cities-based principal in Fish & Richardson's life sciences litigation practice.
U.S. Department of Labor
Read full article
U.S. District Court for the District of
Minnesota
3 Telework Tips For Solos And Small Firms Amid COVID-19
U.S. District Court for the Eastern
Solo practitioners and small law firms facing disruptions from the coronavirus
District of Michigan
pandemic should keep these three simple tips in mind.
U.S. District Court for the Middle
Read full article
District of Florida
Analysis
U.S. District Court for the Northern
District of New York
Del. Chancery Is Uniquely Suited For Coronavirus Response
Delaware's Chancery Court, known far and wide for its expertise handling
U.S. District Court for the Northern
District of Texas
complex corporate litigation, may be more well-positioned than other courts
to handle complications related to the novel coronavirus pandemic, legal
U.S. District Court for the Southern
experts and litigators say.
District of Florida
Read full article
U.S. District Court for the Southern
District of New York
Legal Counsel Official For DC Mayor Dies From COVID-19
U.S. Supreme Court
An official who worked in the legal counsel office for Washington, D.C., Mayor
United States District Court for the
Muriel Bowser has died from COVID-19, the mayor's office announced on
Southern District of Georgia
Friday.
Wage and Hour Division
Read full article
World Health Organization
Kelley Kronenberg Accused Of Shorting Italian Atty's Pay
Kelley Kronenberg PA stiffed an Italian attorney on tens of thousands of
dollars in pay after messing up his work visa and not paying him for the work
he performed while in Italy, the lawyer contended Friday in Florida federal
court.
Read full article
GC Cheat Sheet: The Hottest Corporate News Of The Week
The general counsel of a video gambling giant will give up his pay to soften
the blow for his company during the ongoing pandemic, and the U.S.
Securities and Exchange Commission has offered a road map for COVID-19
risk disclosures. These are some of the stories in corporate legal news you
may have missed in the past week.
Read full article
In Case You Missed It: Hottest Firms And Stories On Law360
For those who missed out, here's a look back at the law firms, stories and
expert analyses that generated the most buzz on Law360 last week.
Read full article
Podcast
EFTA00032904

=== Page 5 ===
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=== Page 1 ===
Jeffrey Epstein released from jail today: won't have electronic monitoring device during y... Page 1 of 4
PailmBeachDailyNews.com
PRINT THIS
THE $8183
Powered by
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Jeffrey Epstein released from jail today: won't have electronic monitoring device during year's
probation
By MICHELE DARGAN
Daily News Staff Writer
Tuesday, July 21, 2009
Updated 8:30 p.m. Wednesday
RELATED LINKS
Convicted sex offender Jeffrey Epstein, released from jail
shortly after 6 a.m. Wednesday, will not be tracked by an
More Jeffrey Epstein case
electronic monitoring device during his one-year
coverage
probation, according to a court order.
National Sex Offender Public
Website
Epstein, who served less than 13 months of his 18-month
sentence at the Palm Beach County Stockade, will serve
one year of probation at his El Brillo Way home. He
already has registered as a sex offender.
In addition, Epstein, who has been out of jail on work
release for 16 hours a day, six days a week since
October, has been going to his Palm Beach home as well
as his West Palm Beach office for the past two weeks.
His attorney, Jack Goldberger, as well as Palm Beach
County Sheriff's Office records confirm that Epstein has
been to his home on several occasions. Goldberger said
Epstein was given PBSO permission to be at home for
Palm Beach Post Photo by Lannis
specific time periods in order to make the transition from
Waters
jail to his home
(enlarge photo)
Jeffrey Epstein is whisked away
The plea agreement stipulated that Epstein, a billionaire
from the Palm Beach County jail in
financier, would not be placed on electronic monitoring,
a black car shortly after 6 a.m.
Goldberger said. An earlier court order incorrectly had
today. Epstein left the jail through
him listed as having to be monitored.
the sally port, where prisoners are
brought in, rather than through the
"A very difficult part in his life is ending, and he is looking
main doors where prisoners are
forward to moving on," Goldberger said.
routinely released.
Epstein, 56, pleaded guilty to procuring a minor for
prostitution and soliciting prostitution.
5/2 http://gox 8 1569 059
priotthis
7/23/2009
2009-07-23 10:15
MM22-FAX FROM PALM BEACH POLICE DEPARTMENT 02-000002
EFTA00031937

=== Page 2 ===
Jeffrey Epstein released from jail today: won't have electronic monitoring device during Page 2 of 4
More than a dozen young women, who were minors at
the time of their encounters, are suing Epstein for sexual
abuse. Among them: Jane Doe No. 3 and Jane Doe No.
5, who both say they fear Epstein and believe he should
have gotten a much harsher sentence. Both women have
filed federal lawsuits.
Doe No. 3, who was 16 at the time of her encounter with
Epstein, said she was shocked to learn Sunday that the
Daily News Photo by Jeffrey
Palm Beach resident was getting out of jail early. She
Langlois
said she also didn't find out he was on work release until
months after the fact.
(enlarge photo)
Jeffrey Epstein's Palm Beach
home on El Brillo Way.
I'm afraid of seeing him'
"I'm scared to go to Palm Beach because I'm afraid of seeing him out in public," said Doe No
3. now 21. "They say, 'once a sex offender, always a sex offender.' What makes them think
he won't do it again? I'm afraid for future victims I believe every one of his victims is grieving
and the justice system did not do justice for his victims."
Doe No 5 was 16 at the time of her one encounter. She is now 22 and has a young daughter.
whom she wants to protect
"It's really upsetting to me," she said. "I'm scared. He's such a powerful man. and I don't know
what he's capable of. I would have liked to see him get a longer jail term. He just got a slap on
the wrist and what he has done to all of us is never going to leave us."
She said that she gets upset when she hears people accuse the victims of being all about the
money.
"It's about getting justice," she said. "He's acting like he's the victim and he walks away. I
couldn't talk about it for a long time. I have flashbacks. I thought it was all my fault for a long
time and that's the way he wanted me to feel."
Miami attorneys Adam Horowitz and Stuart Mermelstein represent Jane Does No 2 through
No. 8 in federal lawsuits.
"We're outraged that a registered sex offender has such a short sentence," Horowitz said.
"They put people in jail for longer periods of time for much lesser offenses. Through his guilty
admission he has acknowledged that he's a sex offender. Our clients have a life sentence of
dealing with his abuse and he gets a slap on the wrist."
West Palm Beach attorney Spencer Kuvin represented Jane Doe No. 1. who has settled her
lawsuit. Kuvin said he could not disclose the amount because of a confidentiality agreement.
But he did say that she didn't want to be in the public eye anymore.
"She was not happy with the resolution," Kuvin said, "but she wanted it over. He's got
investigators in the civil cases trying to dig up dirt on every one of his accusers. The
disgusting thing is that he pleads the fifth on everything that's been asked of him and now he
7/23/2009
5/2 1569
2009
MM22-FAX FROM PALM BEACH POLICE DEPARTMENT 02-000003
EFTA00031938

=== Page 3 ===
"A man with unlimited wealth can hire people to follow her, dig into every crevice of her
personal life and re-victimize her all over again. A convicted pedophile released on the
streets? This would never, ever happen if this was someone of normal or lesser financial
means. He absolutely got special treatment because he's wealthy."
Conditions of Jeffrey Epstein's one-year probation:
* Must register as a sex offender.
* Will not be electronically monitored.
* Shall have no unsupervised conduct with minors, and the supervising adult must be
approved by the Department of Corrections.
. Shall submit to a mandatory curfew from 10 p.m. to 6 a.m.
*
Shall not live within 1,000 feet of a school, day care center, park, playground or other place
where children regularly congregate.
* Shall not have any contact with the victims directly or indirectly, including through a third
person.
R Shall not view, own or posses obscene, pomographic or sexually stimulating visual or
auditory material.
* Shall not work or volunteer in any school, day care center, park, playground or other place
where children regularly congregate.
* Shall meet with probation officer a minimum of once a week.
* Shall submit to a warrantless search by probation officer of person, residence or vehicle.
Source: Court file
Find this article at:
Check the box to include the list of links referenced in the article.
printhis ept&title Jeffrey Epstein released+ 7/23/2009
561 650 6951 D 4/5
2009-07-23 10:20
MM22-FAX FROM PALM BEACH POLICE DEPARTMENT 02-000004
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=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
August 16, 2019
REPLY TO
ATTN OF:
,
M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
, Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for August 15, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported Correctional assignment Internal #2
vacated, due to, a shortage of staff.
Day Watch Shift:
Lt.
reported Correctional assignments Phone Monitor, 10-
South #2, Rec. Officer #1, Rec. Officer #2 vacated, due to, a
shortage of staff.
Evening Watch Shift:
Lt.
reported I/M
placement on the
Special Housing Unit for a serious assault on staff at MDC
Brooklyn.
CONFIDENTIAL
SDNY_00009089
EFTA00033671

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M
on Psych Obs. w/inmate companion
I/M
Suicide Watch w/inmate companion
I/M
on Suicide Watch w/inmate companion
I/M
Pend. Class/Bed Space (CIMS)
NEW ADMISSIONS TO MCC New York:
RELEASED FROM MCC NEW YORK:
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
(Frm. HA)
"
(Code #101)
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
Attorney Conference
Education/Recreation
Central Tool Room
Sallyport 2
MISSING EQUIPMENT INVENTORY FORM:
Attorney Conference
Sallyport 2
Sallyport 3
Roof Recreation
CONFIDENTIAL
SDNY_00009090
EFTA00033672

=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIZED:
FURLOUGH: 00
ANNUAL LEAVE: 08
SICK LEAVE: 09
OFFICIAL TIME: 02
MILITARY LEAVE: 01
FFLA: 00
FMLA: 00
COP: 03
AWOL: 10
ADVANCE LEAVE: 00
LWOP: 01
ADMIN LEAVE: 00
COMP TIME: 02
TRAINING: 04
GLYNCO: 00
LWOP (M) : 03
TOA: 00
EPO: 00
TRAVEL: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 30
Hours = 199.00
E-1 COMPTIME:
Number of staff = 03
Hours = 15.15
60-Q OVERTIME (USM MEDICAL) :
Number of Staff = 00
Hours = 00.00
CONFIDENTIAL
SDNY_00009091
EFTA00033673

=== Page 4 ===
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
08-15-2019 / 12:00 AM
UNIT B-A: 26
UNIT E-N: 77
UNIT E-S: 81
UNIT G-N: 79
UNIT G-S: 87
UNIT H-A: 04
UNIT I-N: 85
UNIT K-N: 91
UNIT K-S: 143
UNIT Z-A: 69
UNIT Z-B: 05
TOTAL:
757
CONFIDENTIAL
SDNY_00009092
EFTA00033674


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=== Page 1 ===
From: Nicole Simmons
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
,
Laura Menninger
"
"
"
,
11
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Motions in
Limine]
Date: Tue, 19 Oct 2021 03:40:55 +0000
Attachments: Maxwell's_Motions_in_Limine.zip
Inline-Images: image001.jpg
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Motions in Limine and supporting documents.
Regards,
Nicole Simmons
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
80203
www.hmflaw.com
EFTA00032796


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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
US Passport (P)
08/19/2019 09:26 EDT
Generated By:
Page 1 of 1
Passenger Information
Last Name
First Name
DOB
Gender
M - Male
US Passport Information
Passport #
Passport Status
Document Type
I - ISSUED
P - - PASSPORT
Issue Country
Issue Date
Expiration Date
USA UNITED STATES
Personal Information
Last Name
First Name
DOB
Gender
Place of Birth
Nationality
M - Male
USA - UNITED STATES
SDNY_MT_00000184
For Official Use Only / Law Enforcement Sensitive
EFTA00033566


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=== Page 1 ===
I would feel really uncomfortable doing this.
>>>
7/23/2019 10:17 PM >>>
The purpose of this email is to inquire as to whether or not inmate Epstein, Jeffrey #76318-054 is mentally capable of proceeding with
the disciplinary process. Thanks in advance.
CONFIDENTIAL
SDNY_00009891
EFTA00034028


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=== Page 1 ===
Epstein 76318-054
7-30-19
5.00
inmate Epstein IS sleeping
5:06 am
Inmate Epstein is awake sitting on bed
Sam
(1)
inmate Epstein is skeping
5:am
Inmate Epstein is sleeping
5:49
am
inmate Epstein 15 sleeping
61 am
inmate Epstein IS sleeping
6:15
'am
am
inmate fostein IS sleeping
6:30m
inmate Epstein D awake
6.45
am
inmete Gystein is talking to me aboc
jail life
7.00
fam
inmate Epstein its cating breakfast
7:00m
fnd of shift
AM
7100
Start of mew Shift
5/m Epstein is having breakfast Cereal and Malk Rn
7:15AM 7:15 AM
For Epstein is a Steel eating
7/30/19 I/w
7:30 AM
The 4/7 give the I/M breakfast the brown long RM
7:45AM
I/m Epstern is setting dow n on his bed-RM
752Am
avier L., X intension
Spetem
8 Am
5t its interialing
3 15 Am
Psy.h claimstion it being discutant


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Wed, 08 Apr 2020 17:46:01 +0000
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still be
grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
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.
EFTA00032202

=== Page 2 ===
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,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
)
^
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Maurene -
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
EFTA00032203

=== Page 3 ===
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein and
Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00032204


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=== Page 1 ===
From:Access to Justice Law360 <news@law360.com>
To:<
Subject:How Defense Sleuths Are Forging Ahead Despite A Pandemic
Date:Mon, 20 Apr 2020 11:27:38 +0000
Law36
Access to Justice
0 Access
to
Justice
Young2.jpg
Monday, April 20, 2020
LAW FIRMS
How Defense Sleuths Are Forging Ahead Despite A Pandemic
Arent Fox
Across the country, thousands of investigators who help build cases for indigent
defendants are adjusting to a new reality in which field work is "pretty much shut
Ashurst LLP
down." Though arrests have slowed and many court proceedings are on hold,
Austin LLP
investigators say their work can't stop.
Baker Donelson
Read full article
Baker McKenzie
Ballard Spahr
Barnes & Thornburg
Victims' Rights Suffer Blow In Epstein Case
Bast Amron
In the latest twist in the Jeffrey Epstein saga, a split Eleventh Circuit panel ruled
Belkin Burden
last week that the protections of the Crime Victims' Rights Act do not arise until
Blank Rome
after a formal criminal charge has been filed. For Epstein's victims, it could mark
the end of a 12-year-long legal challenge - and for the victims' rights
Boies Schiller
movement, it could be a lasting blow.
Bracewell
Read full article
Brown Rudnick
Bryan Cave Leighton
Paisner
Virus Forces Transparency Reckoning Among Highest Courts
Cadwalader Wickersham
Since coronavirus concerns shuttered courthouses nationwide, the U.S.
Cahill Gordon
Supreme Court and some appellate judges have given in to livestream
Clifford Chance
technology. Transparency advocates welcome this development and hope the
practice will continue even after the pandemic ends.
Clyde & Co
Read full article
Cooley
Covington & Burling
Cravath Swaine
Analysis
Crowell & Moring
Amid Pandemic, Hearings For Detained Migrant Kids Go On
Culhane Meadows
As federal courts close their doors during the coronavirus pandemic, immigration
DLA Piper
court proceedings for migrant children in government custody are moving
Davis Polk
forward. Attorneys told Law360 that continuing these hearings risks children's
Debevoise & Plimpton
health and threatens due process.
Read full article
Dentons
Duane Morris
Eckert Seamans
EFTA00032906

=== Page 2 ===
Q&A
Eversheds Sutherland
Coping With A Pandemic: Pine Tree's Nan Heald
Faegre Drinker
With distancing and isolation the new norm amid the COVID-19 pandemic,
Fenwick & West
Law360 is sharing reactions from around the business and legal community.
Fisher Phillips
Today's perspective comes from Maine-based Nan Heald, executive director at
Foley & Lardner
Pine Tree Legal Assistance.
Read full article
Foley Hoag
Fragomen Del Rey
Fried Frank
Homeless Angelenos Get Due Process Win Over City Seizures
Fross Zelnick
In January 2019, Janet Garcia returned from getting ready for work to find that
Gibson Dunn
all of her belongings had been seized and destroyed by the Los Angeles Bureau
Goldberg Segalla
of Sanitation.
Goodwin
Read full article
Greenberg Traurig
Greenspoon Marder
Hinshaw & Culbertson
Bail Bond Groups Can't Sink Calif. Price-Fixing Suit
Hodgson Russ
For those who turn to bail bonds in California, the cost of getting oneself or a
Hogan Lovells
loved one out of prison while awaiting a court date can be steep, but a proposed
class action now poised to move forward contends there's more to those rates
Hogan Thompson LLP
than honest market forces.
Holland & Knight
Read full article
Hueston Hennigan
Husch Blackwell
Immigration Law PLLC
Pro Bono Spotlight
Jackson Lewis
O'Melveny Helps Reunite Family Amid COVID-19 Fears
Jones Day
When three young siblings found themselves detained 50 miles from their
K&L Gates
father's home in Maryland, with the government moving to deport them rather
than reunite the family, it was the latest hardship in a journey fraught with
Kelley Drye
danger.
Kilpatrick Townsend
Read full article
Kirkland & Ellis
Klehr Harrison
Lanier Law Firm
Perspectives
Latham & Watkins
COVID-19 Highlights Access Injustice In Personal Bankruptcy
Levenfeld Pearlstein
In the age of enforced social distancing, the limits on access to electronic filing
Lieff Cabraser
means bankruptcy is paradoxically only available to those individuals who can
Linklaters
afford it, says Rohan Pavuluri at Upsolve.
Read full article
Loeb & Loeb
Lowenstein Sandler
Lucas Magazine
Perspectives
Marshall Dennehey
Inmate Release Exhaustion Rule Should Be Waived For COVID
Mason Lietz
The issue at the forefront of many compassionate release applications during
Mayer Brown
the pandemic has been whether federal courts must wait 30 days before they
Mintz Levin
can rule on them due to the statutory administrative exhaustion requirement, and
Morgan Lewis
those 30 days could become a matter of life or death, says Jolene LaVigne-
Mukasey Frenchman
EFTA00032907

=== Page 3 ===
Albert at Schlam Stone.
Nixon Peabody
Read full article
Norton Rose
O'Melveny & Myers
Ogletree Deakins
Orrick
Paul Hastings
Pepper Hamilton
Perkins Coie
Pierce Bainbridge
Pryor Cashman
Reed Smith
Rivkin Radler
Ropes & Gray
Schiff Hardin
Schlam Stone
Seyfarth Shaw
Sheppard Mullin
Shook Hardy
Sidley Austin
Simmons & Simmons
Slaughter and May
Snell & Wilmer
Squire Patton Boggs
Stoel Rives
Thompson HD
Troutman Sanders
Vinson & Elkins
Williams & Connolly
Wilson Sonsini
Winston & Strawn
Womble Bond Dickinson
COMPANIES
3M Co.
Aeropostale Inc.
American Immigration
Lawyers Association
Apple Inc.
Brooklyn Defender Services
Burford Capital LLC
CDI Corporation
Cable News Network Inc.
Ernst & Young LLP
Facebook Inc.
EFTA00032908

=== Page 4 ===
Google Inc.
Instagram Inc.
Johnson & Johnson
Kids in Need of Defense
Legal Aid Foundation of Los
Angeles
Linkedln Corp.
Monsanto Co.
Orleans Public Defenders
Philip Morris International
Inc.
Pine Tree Legal Assistance
Inc.
Skype Technologies SA
Sonos Inc.
Spotify Technology SA
The Walt Disney Co.
Twitter Inc.
GOVERNMENT
AGENCIES
California Department of
Insurance
California Supreme Court
Executive Office for
Immigration Review
Federal Trade Commission
Food and Drug
Administration
Los Angeles Homeless
Services Authority
New Jersey Office of the
Public Defender
New Jersey Supreme Court
Occupational Safety and
Health Administration
Pennsylvania Supreme
Court
Securities and Exchange
Commission
Small Business
Administration
U.S. Attorney's Office
U.S. Court of Appeals for
the Second Circuit
U.S. Court of Appeals for
the Third Circuit
EFTA00032909

=== Page 5 ===
U.S. Department of Health
and Human Services
U.S. Department of
Homeland Security
U.S. Department of Justice
U.S. Department of Labor
U.S. Department of the
Treasury
U.S. District Court for the
Southern District of New
York
U.S. Immigration and
Customs Enforcement
U.S. Supreme Court
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EFTA00032910


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=== Page 1 ===
90A-NY-3151227 Serial 59
1 = of 2-
FD-302 (Rev. 5-8-10)
FEDERAL BUREAU OF INVESTIGATION
Date of entry 08/27/2019
CHILD VICTIM AND CHILD WITNESS IDENTITY INFORMATION
This document contains information regarding a child victim's or child witness's
identity, which may only be disclosed to individuals who have a need-to-know such
information by reason of their participation in the associated proceeding, or if
disclosure is necessary to protect the welfare and well-being of the child.
On August 26, 2019, ITS/Forensic Examiner (FE)
, in
response to MDUS request #10754, a file system extraction was performed on
the following device using GrayKey v1.11.10:
Device: Apple iPhone XS
Model: A1920
iOS: 12.4
IMEI:
IB Number: 1B44
No Unlock PIN was associated with this device.
A SHA256 hash was generated on the extraction file and saved. All extraction
files were copied to an external hard drive.
The file system extraction was performed under legal authority attached.
The submitted item and CART-generated derivative evidence returned to
assigned CART Examiner. New York CART considers this portion of the
examination complete.
Investigation on 08/26/2019 at New York, New York, United States (In Person)
90A-NY-3151227, 268-HQ-C7772046-DEVICES UNLOCKED, 321C-NY-
File # A6382037-MOBILE
Date drafted 08/27/2019
by
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not
to be distributed outside your agency.
SDNY_MT_00000199
EFTA00033568

=== Page 2 ===
90A-NY-3151227 Serial 59
FD-302a (Rev. 5-8-10)
90A-NY-3151227
Continuation of FD-302 of (U) Device Extraction - MDUS 10754
,On 08/26/2019 1 Page 2 of 2
SDNY_MT_00000200
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=== Page 1 ===
I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M companion was utilized).
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
CONFIDENTIAL
SDNY_00009584
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=== Page 1 ===
From:
To:
Subject: Epstein indictment
Date: Mon, 08 Jul 2019 18:55:31 +0000
Hello, I am a law professor.
I note that the forfeiture is being done under a special Human Trafficking statute. In paragraph 25 of the indictment, you
refer to 18 USC 1594(c)(1). But you meant 1594(d)(1). 1594(c)(1) does not exist.
Typos in indictments have disastrous consequences, as I am sure you know. So you might want to correct this.
EFTA00032974


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c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032506.pdf
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c7: images
c0:
=== Page 1 ===
From:
SANYS)"
To:
)"
Subject: Prosecutors Broke Law In Epstein Plea Deal, Fla. Judge Says
Date: Fri, 22 Feb 2019 13:12:28 +0000
Importance: Normal
close
Prosecutors Broke Law In Epstein Plea Deal, Fla. Judge Says
By Carolina Bolado
Share us on:
Law360 (February 21, 2019, 5:58 PM EST) --
Prosecutors, including then-U.S. Attorney and current
Labor Secretary Alexander Acosta, violated the
Crime Victims' Rights Act when they signed a non-
prosecution agreement with billionaire sex offender
Jeffrey Epstein without notifying his victims, a
Florida federal judge ruled Thursday.
Prosecutors failed to comply with their obligations to
inform the victims of Jeffrey Epstein, shown in 2004,
that they intended to enter into an agreement not to
prosecute him, a judge said Thursday. (Getty)
U.S. District Judge Kenneth A. Marra granted
summary judgment to two Epstein victims who sued
the government over the deal and said federal
prosecutors failed to comply with their obligations
under the CVRA to inform Epstein's victims that they
intended to enter into an agreement not to prosecute
him.
The government's decision to hide its intentions and
to tell victims to just be patient with the investigation
was "particularly problematic," according to the
judge.
EFTA00032506

=== Page 2 ===
"When the government gives information to victims,
it cannot be misleading," Judge Marra said. "While
the government spent untold hours negotiating the
terms and implications of the NPA with Epstein's
attorneys, scant information was shared with victims.
Instead, the victims were told to be 'patient' while the
investigation proceeded."
Judge Marra rejected the government's claim that the
CVRA requires victims to be notified only of a plea
bargain or a deferred prosecution agreement, both of
which are more common than a non-prosecution
agreement, according to the opinion. But that reading
of the law is "inconsistent with the goal of the
CVRA," the judge said.
"The expansive context of the CVRA lends itself to
only one interpretation; namely, that victims should
be notified of significant events resulting in
resolution of their case without a trial," Judge Marra
said.
The ruling is a big win for the two Epstein victims,
listed as Jane Does, who sued the government in
2008 alleging the U.S. Attorney's Office for the
Southern District of Florida violated the CVRA with
the Epstein deal.
The CVRA grants crime victims a number of rights,
including the right to be informed of public court
proceedings and not to be excluded from those
proceedings. The Miami Herald, in an investigative
report published late last year, printed emails
showing that the alleged victims were deliberately
excluded from the deal cut between Acosta, who was
then the U.S. Attorney for the Southern District of
Florida, and Epstein's defense team.
Epstein's alleged victims - numbering in the dozens
- claim he lured teenage girls to his Palm Beach,
Florida, mansion to engage in sexual acts. They have
EFTA00032507

=== Page 3 ===
not had the opportunity to testify in court in any
proceeding thus far, according to the Herald report.
Bradley Edwards, who represents the victims suing
the government, called Judge Marra's decision a
"clear victory and long-overdue vindication for all of
the victims."
"It is unfortunate that at no time during the past 10
years has the government acknowledged its clear
violation of the rights of dozens of crime victims,"
Edwards said. "Hopefully now they will stop
defending what was clearly an improper agreement,
apologize directly and unequivocally, and work to
make it right."
Judge Marra said the parties have 15 days to tell the
court how they wish to proceed to determine any
appropriate remedies. Edwards said the primary
remedy is the invalidation of the non-prosecution
agreement.
A U.S. Department of Labor spokeswoman said the
actions of the U.S. Attorney's Office in this case
"have been defended by the Department of Justice in
litigation across three administrations and several
attorneys general." She said any further comment
would have to come from the DOJ.
The U.S. Attorney's Office for the Southern District
of Florida declined to comment.
The DOJ has opened an investigation into whether its
attorneys engaged in misconduct when negotiating
the controversial deal with Epstein, according to a
letter sent earlier this month to Sen. Ben Sasse, R-
Neb., who repeatedly pushed for such an
investigation. The letter said the DOJ's Office of
Professional Responsibility had opened an
investigation into the deal.
EFTA00032508

=== Page 4 ===
It was after reading the investigative report by the
Herald that Sasse became concerned and sent two
letters to the DOJ urging the agency to investigate.
The Herald's three-part series, "Perversion of
Justice," showed how Acosta and other DOJ
attorneys worked closely with defense lawyers to
craft a lenient plea deal for Epstein in 2008.
The series was published just before Epstein was set
to go to trial in a civil dispute with Edwards, who had
filed a malicious prosecution claim against Epstein.
The trial was to have featured testimony from some
of his victims. But just before jury selection was set
to begin, an attorney for Edwards announced a
settlement, while Epstein's attorney read an apology
from his client to Edwards.
The victims are represented by Bradley Edwards
of Edwards Pottinger LLC, Jay C. Howell of Jay
Howell & Associates PA, John Scarola of Searcy
Denney Scarola Barnhart & Shipley PA and Paul G.
Cassell of the University of Utah's S.J. Quinney
College of Law.
The government is represented by Ann Marie C.
Villafana and Dexter Lee of the U.S. Attorney's
Office for the Southern District of Florida.
The case is Doe et al. V. U.S., case number 9:08-cv-
80736, in the U.S. District Court for the Southern
District of Florida.
--Additional reporting by Lauren Berg. Editing by
Nicole Bleier.
EFTA00032509


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032385.pdf
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=== Page 1 ===
From:
"
"
To:
(NY) (FBI)"
)"
)"
,
)"
Subject: Re: Interview notes
Date: Thu, 15 Aug 2019 21:27:05 +0000
Attachments:
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
(NY) (FBI)
Sent: Thursday, August 15, 2019 4:25:26 PM
To:
is
)
is
Cc:
Subject: Interview notes
SA
FBI New York
VCAC/HT
C:
O:
EFTA00032385


c1: EFTA00032422
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032422.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(OIG)"
(USANYS)"
(USANYS)"
(OIG)"
Cc:
(NY) (OGA)"
Subject: Finalized 302
Date: Fri, 30 Aug 2019 16:52:12 +0000
Attachments
302.pdf
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00032422


c1: EFTA00031945
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00031945.pdf
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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Meeting Forward Notification: Call re: Epstein FOIA
Date: Fri, 19 Mar 2021 13:09:22 +0000
Your meeting was forwarded
(USANYS) has forwarded your meeting request to additional recipients.
Meeting
Call re: Epstein FOIA
Meeting Time
Friday, March 19, 2021 9:00 AM-9:30 AM.
Recipients
(OGC) (FBI)
All times listed are in the following time zone: (UTC-05:00) Eastern Time (US & Canada)
Sent by Microsoft Exchange Server
EFTA00031945


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032092.pdf
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=== Page 1 ===
BP-A0971
CHAIN OF CUSTODY LOG CDFRM
AUG 11
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
ECN # NYM-19-0174
(Enclose with/attach to evidence)
ITEM # NYM-19-00185 W
DESCRIPTION CASE ID NUMBER: OF ITEM: (1)torn Sheet miscellaneous paperwork MP3Player
SUSPECT (If known) Jeffey Epstain#
Clothing released 8/10/19@ 3.11P4 from Hospital (one bag Plastic)
DATE/TIME ITEM FOUND:
LOCATION: Special Housing Unit L-Tier Cell #220
SIGNATURE OF PERSON RECOVERING EVIDENCE:
PRINTED NAME:
EVIDENCE PLACED IN OVERNIGHT DROP BOX:
DROP-BOX BY: (printed name)
Date & Time:
Witness: (printed name)
EVIDENCE RECOVERED FROM OVERNIGHT DROP BOX BY:
(printed name)
Date & Time:
Witness: (printed name)
EVIDENCE PLACED EVIDENCE SAFE BY:
(printed name)
Date & Time:
Witness: (printed name)
DISPOSITION:
( )
Hold as evidence
(
)
Return to owner
( )
Lab Analysis
( )
Return to finder
(
)
Destroy immediately
( )
FBI
( )
Other
REMARKS (condition of evidence):
CHAIN OF CUSTODY
EVIDENCE RELEASED BY:
DATE/TIME:
DESTINATION:
EVIDENCE RELEASED TO:
8/10/19 3:40Am
FBI
PDF
Prescribed by P5510
EFTA00032092

=== Page 2 ===
BP-A0971
CHAIN OF CUSTODY LOG CDFRM
AUG 11
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
ECN # NY4-19-0175
(Enclose with/attach to evidence)
ITEM # NYM-19-00183
CASE ID NUMBER:
DESCRIPTION OF ITEM: (1) home made Noose
SUSPECT (If known) Jeffrey. Epstein
DATE/TIME ITEM FOUND: 8/10/19@3:11pm
LOCATION: Special Housing Unit L-TieR cell #20
SIGNATURE OF PERSON RECOVERING EVIDENCE:
XPRINTED NAME:
EVIDENCE PLACED IN OVERNIGHT DROP BOX:
DROP-BOX BY: (printed name)
Date & Time:
Witness: (printed name)
EVIDENCE RECOVERED FROM OVERNIGHT DROP BOX BY:
(printed name)
Date & Time:
Witness: (printed name)
EVIDENCE PLACED EVIDENCE SAFE BY:
(printed name)
Date & Time:
Witness: (printed name)
DISPOSITION:
( )
Hold as evidence
(
)
Return to owner
( )
Lab Analysis
( )
Return to finder
(
)
Destroy immediately
( )
FBI
( )
Other
REMARKS (condition of evidence):
CHAIN OF CUSTODY
EVIDENCE RELEASED BY:
DATE/TIME:
DESTINATION:
EVIDENCE RELEASED TO:
PDF
Prescribed by P5510
EFTA00032093

=== Page 3 ===
BP-A0971
CHAIN OF CUSTODY LOG CDFRM
AUG 11
U.S.
DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
ECN #
(Enclose with/attach to evidence)
ITEM # NYM-19-00182
CASE ID NUMBER:
SUSPECT (If known) Jeffrey, Epstein#76318-154
DESCRIPTION OF ITEM: Clothing Epstein was transported to outside hospital with.
DATE/TIME ITEM FOUND: August 10, 2019 2 10:15 AM
New York Presbyterian Hospital
LOCATION: SIGNATURE OF PERSON RECOVERING EVIDENCE: One One sh
De
PRINTED NAME:
EVIDENCE PLACED IN OVERNIGHT DROP BOX:
DROP-BOX BY: (printed name)
Date & Time:
Witness: (printed name)
EVIDENCE RECOVERED FROM OVERNIGHT DROP BOX BY:
(printed name)
Date
& Time:
Witness: (printed name)
EVIDENCE PLACED EVIDENCE SAFE BY:
(printed name)
Date
& Time:
Witness: (printed name)
DISPOSITION:
( ) Hold as evidence
( ) Return to owner
(
)
Lab Analysis
( ) Return to finder
( ) Destroy immediately
(
) FBI
( ) Other
REMARKS (condition of evidence) :
CHAIN OF CUSTODY
EVIDENCE RELEASED BY:
DATE/TIME:
DESTINATION:
EVIDENCE RELEASED TO:
Derrick Mebane
8/10/19 10:32AM
SIS Office
SIS Lt. T. Doctor
PDF
Prescribed by P5510
EFTA00032094


c1: EFTA00031994
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00031994.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(OIG)"
To:
(USANYS)"
(NY) (OGA) (FBI)"
(NY) (FBI)"
Cc:
(USANYS)"
Subject: RE: Sign in SHU
Date: Mon, 27 Jul 2020 18:19:59 +0000
Thank you for that clarification. I will talk to
and set it up.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
(Office)
(Cell Phone)
From:
(USANYS)
Sent: Monday, July 27, 2020 2:19 PM
To:
(OIG)
is
(NY) (OGA) (FBI)
;
(NY) (FBI)
Cc:
(USANYS)
Subject: RE: Sign in SHU
You should reach out without me and
Whenever works for you and
If she declines a voluntary
interview, which would surprise me, then let's discuss further before doing anything.
From:
(OIG)
Sent: Monday, July 27, 2020 12:03 PM
To:
(USANYS)
is
(NY) (OGA) (FBI)
>;
(NY) (FBI)
Cc:
(USANYS)
Subject: RE: Sign in SHU
Copy. I can set it up via phone for later this week or next week.
and
can you please give me days and
times that work for you? After I have your availability options, I will then call
to schedule.
if
declines a voluntary interview, do you want me to compel her?
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
(Office)
(Cell Phone)
EFTA00031994

=== Page 2 ===
From:
(USANYS)
Sent: Monday, July 27, 2020 11:55 AM
To:
(OIG)
is
(NY) (OGA) (FBI)
(NY) (FBI)
Cc:
(USANYS)
Subject: RE: Sign in SHU
Thank you. The record came from Associate Warden
Will you please reach out to her, give her the
standard voluntariness warning, and ask her where the sign came from? Can you please ask how she got it, whether she
took it from the SHU, and when. Can you also ask who created it and hung it up? It is possible she was given this
document by someone else and won't know the answer to the majority of these questions. If that's the case, we'll want
to find out who had the sign / who knows the information and interview that person. If, on the other hand, she is
knowledgeable about the sign (including why it was hung and who took it down and when),
and I will want to
interview her by phone. Of course, do a 302/MOI. Thanks very much and let us know if you have any questions.
From:
(OIG)
Sent: Monday, July 27, 2020 10:53 AM
To:
(USANYS)
is
(NY) (OGA) (FBI)
is
(NY) (FBI)
Cc:
(USANYS)
Subject: RE: Sign in SHU
No problem, just let me know
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
(Office)
(Cell Phone)
From:
(USANYS)
Sent: Monday, July 27, 2020 10:40 AM
To:
(OIG)
is
(NY) (OGA) (FBI)
is
(NY) (FBI)
Cc:
(USANYS)
Subject: RE: Sign in SHU
Ok, thanks. We've asked the FOIA attorney who was the custodian of this record, and once we know, we're going to need
to interview that person, which we may ask you to facilitate.
From:
(OIG)
Sent: Monday, July 27, 2020 10:39 AM
To:
(USANYS)
is
(NY) (OGA) (FBI)
is
(NY) (FBI)
Cc:
(USANYS)
Subject: RE: Sign in SHU
EFTA00031995

=== Page 3 ===
I re-read the FBI 302s and the DOJ OIG MOIs. There was no mention of any signage, posters, written unique instructions,
or anything that fit the description of what was provided from you.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
(Office)
(Cell Phone)
From:
(USANYS)
Sent: Sunday, July 26, 2020 11:11 PM
To:
(NY) (OGA) (FBI)
is
(NY) (FBI)
>;
(OIG)
Cc:
(USANYS)
Subject: Sign in SHU
Hi folks,
I have a recollection that when we were interviewing employees at the MCC, one or more individuals told us there was a
sign posted in the SHU that said to do your checks on Epstein. If memory serves, we never recovered the document. But
last week we got a production of records from the BOP as part of FOIA litigation that included the attached. Can you
remind us (a) if there was in fact some employee who told us about this sign - I haven't looked at all the 302s and MOIs,
and (b) of anything we did to try to get this sign previously (if we did in fact make inquiries).
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
Cell:
EFTA00031996


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=== Page 1 ===
PSYCH OBSERVATION LOG
NAME: Epstein
REGISTRATION#: 76318-054
OBSERVATION STARTED: 7/8/19@ 6PM
OBSERVATION ENDED: 7/10/19 9 AM
PLEASE RETURN LOG TO PSYCHOLOGY AFTER
THE OBSERVATION HAS ENDED.
THANK YOU.
ITEMS ALLOWED:
Regular Clothes
Safety Toothbrush
Newspaper/Magazine
Books (softcover only)
Safety Pen and Paper
Toilet Paper
Legal Mail
Other
SW Blanket & SW Mattress must be used even on
Psych Observations.
If nothing is checked with a silver marker, only a
Suicide Smock and Suicide Blanket are allowed.
CONFIDENTIAL
SDNY

=== Page 2 ===
Name of Inmate On Suicide Watch or Psych Observation: Epstein
Registration #: 76318-054
EATING/SHOWER CHART
DATE
BREAKFAST
LUNCH
DINNER
LIQUIDS
OFFERED
RECEIVED
7-9-19
A
A
SHOWER
SHOWER
7/10/19
Please check the appropriate box if the person on
Suicide Watch/Psych Observation actually eats his
meal. Do not check the box if he just received it,
but did not eat it.
Place a check in the "Liquids" box each time the
person drinks.
Thank you.
CONFIDENTIAL
SDNY_00009720
EFTA00033967

=== Page 3 ===
7/8/19 Epstein 76318-054
6:00PM Inmate Companion Jeffrey Weber 85377054
assumes the responsibility for # the Psych Watch
shift for Inimate Epstein 76318-054 in cell #4
on 7/8/19 at 6 PM Jeffrey Waler
SW
6:15PM Ininate Epstein is desking to I/EWeber about
the kinds of crazy things he has seen ds an I/C
JW
6.30PM Inmate Epstein is asking I/C Weber abat He J.W. how life
isupstairs in a General Population Unit compared to the SHU) SW
6:45PM Ininate Epstein is sitting quietly on his bed.
7:00PM Inmate Epstein is lying quetly in bed
JW
7:15PM Inmate Epstein is sleeping
JW
7:30PM Inmate Epstein is sleeping
JW
7:45PM Inmate Epstein is sleeping
SW
8:00PM Inmate Epstein is sleeping
JW
8:15PM Inmate Epstein is sleeping
JW
8.30PM Imate Epstein is sleeping
SW
8:45PM Ininate Epstein is sleeping
SW
9:00PM Inmate Epstein is lying quetly in bed
SW
9:15PM Immate Epstein is pacing around in his cell.
JW
9:30PM Inmate Epstein is pacing around in his cell.
JW
9:45PM Inmate Epstein is lying quitly in bed
SW
10:00PM Inmate Epstein appears to be stee ping
SW
10:15PM Inmate Epstein appears to be sleeping
SW
CONFIDENTIAL
SDNY_00009721
EFTA00033968

=== Page 4 ===
7/8/19 Epstein 76318-054
10:30PM Inm ate Epstein is sleeping
SW
10:45PM Inmate Epstein is sleeping
DW
11:00PM Endof of shift for Inmate Companion Weber
85377-054 Jeffrey Weler
SW
Lt ROS
113R Inmate BRANDON DeCAPUA #16520-055
assumes responsibility for thepsych
observation of hmate EASTEIN#76318-054
in cell#4 ON 7/8/19 at 1100 pm Bhanks BD
1115pm / mate EPSTEIN IS SLEEPING
BD
1125m Imate EPSTEIN is laying down, / asked if
1123pm Imate EPSTEIN IS up using bathroom
BD
heate dinner becauseds not logged.-
He said hawas offered disner
130 lmete EBSTEIN is ayingdown
refused because it was rasty (Heisright)RD is BD
Ien 145 Imate EBSTEIN is laymodowns
BD
120AM Staffrounds
12AM Immate EPSTEIN is sleeping
BD
BD
12'AM Imate EPSTEIN is awake pacing cell
BD
1230 Inmate EPSTEIN is paceing, used bathroom,
then lays down
BD
12th AM is paceing his cell
BD
CONFIDENTIAL
SDNY_00009722
EFTA00033969

=== Page 5 ===
100m 05 Immate EPSTEIN is laying down
AM Inmate EPSTEIN is paceing his cell
0000
B
AM 15 25 lamate EPSTEIN IS paceinghis cell
BD
AM Staff rounds
BD
\ m HM POP
130 trmate EPSTEIN is pacingcell
BD
45 45AM AM Immate EPSTEIN is talking to me and I'm
him explaining prisonlifeard ettiquite to -
BD
26AM $15 Still explaining
BD
730 AM Still explaining
BD
AM Still explainiquation prisons, the basics
of whats what, who's who, and how's
how.
BD
23 Class down is over lamate EPSTE IN is laying
BD
2 Am End of Shif FB sleeping
245 Imate EPSTEIN is
BD
&
Allev WAlker started stift 86900 054
AW
3'AMIM Epstein APPEARS to be sleep
AW
3:32PM Epstein APPRAS to be sleep
AW
3434IM Epstein is using the BAthrouM
A.W
1.00AMI/M Epstein is lAying DOWN
AW
CONFIDENTIAL
SDNY_000097:
EFTA00033

=== Page 6 ===
7-9-2019
F
EpsteiN 76318-054
4:AM I/M EpsteiN is PACING his cell
AW
14:3AMI/M Epstein IS PAcing his cell
AW
4045 4.AM I/M Epstein is sltting up
AW
5:Am I/M Epstein is reAdy for breakfast.
AW
SiAM I/M Epstein is lAying DOWN
AW
POAN 530 I/M Epstein is LAYING DUWN
An
5.45 AM I/M Epstein is LAying DOWN
A.W
6.AM I/M Epstein IS laying DOWN
AN
BAn 15 I/M Epstein is 14ying DOWN
Aw
16:30n 45 I/M Opstein IS Aying Dohn
Adv
6.Am I/M Epstein IS ready for breakfas
Ail
7:Am I/C Alien WAlker 86900-054 Shift ENDS
AV
AM
D/h Lt Dut 7-9-19
7:00 start
ift Rachard Marti Nez 4775805
70A In
box
Psych visit + review of by by
7154
A
8n
feving.
Eng
730 In
245 Das Q
8:00 F/M Epstein is setting Intervey down on the bed
namely
EM
Eng
R
8:15
-/M Epstein is pacing his all
RM
8:20' An For Eptein is going for Visit
RM
8:30 F/M EPSteiN is on Visit
e
CONFIDENTIAL
SDNY_0000
FFTA000

=== Page 7 ===
EPstein # 76318-054
8:45 A I/M Epstein Still out
RM
9:00 Au F/M Epstein Still out
RM
9.15 7/4 stell out
RM
9:30AM F/M Epstein still out
RM
9:45 DM 5/m Epstern Still out
RM
0:00 All I/M Epstein still out
PM
10:15 AM For Epstein Still out
RM
10:30 AM I/M Epstein still out
RM
10:45 I/M Epstein still out
An
RM
11.00 DM I/M Epstern Still out
RM
11:15 AM I/m Epatem Stell out
RM
11:25 An Inmak companion Dwayne Carley Assures responsibility
86700054
for inmale Epstein 76318-054 whom which DC
11:30AM is still out
PC
11:45 AM Inmate EpskinD is still OUT
DC
1200 PM Inmate Epstein JUST CANE back
Pd
1215 PM
Inmale Epstein is eating lunch
Dd
1230PM * PM Inmale Epstein WAS JUST TAKENTO see Poctor DC
1245 Inmate Epstein is still OUT
Dd
100 PM
Inmate Epslexio is stil as Sicell TO Ductor Dd
1:15PM.
Inmate Epstein is still at TO doctor
DC
EpsteiN hAs? Returned
Dd
1:30Pm Inmate Epstein talking to me
Dd
CONFIDENTIAIL
SDNY_00009725

=== Page 8 ===
7/9/19
Cont,
EPSTEIN 76318-054
1:45PM Inmate Epstein is sitting p talking to Me-pc
2:00PM Inmate Epskin WAS TAken out by officer
DC
215PM Inmate Epstein is still at
pc
245PM 2:30PM Inmate Epstein IS still out
Dd
Inmale Epstein IS still at
Dd
3:00Pm Inmate Epstein IS still out
pcl
2
End of s llift 867000521
13:00 INC MILLER 857714054 ASSUMES RESPONSIBILITY
FOR INMATE ESPEPSTEIN #76318-054 cell 4 thy
PSYCH/OBS WATCH
3:00PM INMATE EPSTEIN IS OUT
DM
3:15PM INMATE EPSTEIN Is OUT
DM
3:30 INMATE EPSTEIN IS OUT
DM
3:45PM INMATE EPSTEIN IS OUT
DM
4.00 INMATE EPSTEIN IS OUT
PM
4.15th INMATE EPSTEIN IS OUT
DM
4:30 INMATE EPSTEIN IS OUT
DM
4:45PM INMATE EPSTEIN IS OUT
DM
5:00 PMS INMATE EPSTEIN IS OUT
DM
5:15 INMATE EPSTEIN IS OUT
DM
5:30Pm Lt Rands C. Perez
Cyp
5:30 INMATE EPSTEIN IS OUT
OX
5:45 INMATE EPSTEIN IS OUT
DN
CONFIDENTIAL
SDNY_00009
EFTA0003

=== Page 9 ===
7/9/19 EPSTEIN 76318-054
6:00 INMATE EPSTEIN IS OUT
DM
6:15PM INMATE EPSTEIN IS OUT
DM
6:30PM INMATE EPSTEIN IS OUT
DM
6:45 INMATE EPSTEIN IS OUT
DM
7:00 INMATE EDSTEIN IS OUT
DM
END OF SHIFT
7.00 I/@ amensey # 89673-053 appriming
responsibility for Ilan Epstent#76318-654 619
7:19
Item Epstein is out
4DO
7:30
Tlan Fpsteni is out
409
THE
item Epstery is out
UPA
7:55
Item Episten has returned from his legal
4996
visit
8:00
Ilam Epster and I are tolking abouth your
excorthesives
8:19
Item discussion Exten and are continuing the
will
8:30
I/m Epstein haspansed to brush lus WD09
teeth
8:45
then Epstern and I etalking about have work
to handleprison
9:00
9:5
Ilm Epsten and I are tolking about arbetrago Unw
I/m F.Asten isasking questions about CO's E
CONFIDENTIAL
SDNY_00009727

=== Page 10 ===
9:30 know Ilan Epstoin is talking aboutcelebs he
was
;
9:45 Lt RDS
auy I'm Epstein is asking for his meds
work
10.00 I/cu Epsten just received his ineds
used
10:15 I/m Epstein is asking about kitchen food
400
10:30 I/m Epsten is going to sleys
WOM
10:45 Flue Esstens sleeping soundly
WDC4
11:00 Ilen Epstem outfor thomight Chesaid
4Dad
good night)
10:03 I/C Mersey END SHIFT
WDay
11'm Imate BRANDON DeCAPUA#16520-065 -
observation of limete EPSTEIN
assumestesponsibility.for the psych -
#763,18-054 in cell #4 on 7/9/19 at 11 pm -
BD
11km
Imate EPSTEIN is sleeping
BL
30 AM Inmate EBSTEIN is awake leging pacing
12AM 08 Imate ERTEIN IS pacing
45 ,AM 00 | MeteEPSTEIN IS usingbathroom
B
12 AM Staff SOUNDS
BD
12AM 15 Inmate EASTEIN IS pacing
BD
1230 imate EPSTEIN is pacing
BI
1245 Imate EPSTEIN is pacing
B
CONFIDENTIAL
SDNY_00009728
EFTA00033975

=== Page 11 ===
00
AM
od
AM
Imate EPSTEIN is pacing
BD
112AM
Imate EPSTEIN is laying bounquiet
BD
Lt ROUNDS
BD
\
m
P2
15
AM
3
Imate EPSTEIN is layingdown
AM
45
AM
00
213m
Imate EASTEIN is sleeping
Inmate EPSTEIN is sleeping
Immote EPSTEIN issueeping
Bl
2AM
BI
layingdown
Imate EPSTEIN is using bathroom, then
BD
29AM
45
hmate EPSTEIN 15. pacing
BE
2AM
/mate EPSTEIN 15 pacing
B
300M
3AM
Inmate EPSTEIN 15 packg
End of shift
BD
302
AM
I/C BRISSETT (76269-054) ASSUMES RESPONSIBILITY For
THE PSYCH OBSERVATION OF INMATE EPSTEIN (76318-057)
CELL#4 ON 7/10/19
304
/NIMATE EPSTIEN IS LATING DOWN RIGHTN IN
315
INMATE EPSTIEN IS LAYING Soun
as
INMAN EPSTRON is laych Down
335
INMATE EPSTION is WALKING ARWAND
336
ASKS IF its OKAY For HINTO WALKARWND HES ALSO
TAKINGUA DEE
CONFIDENTIAL
SDNY_00009729
EFTA00033976

=== Page 12 ===
EPSTIEN 76318-054
I
345 INMATE EPSTIEN is Pace BACKALES Furth
If
lurate Erstre- ERSUR pacra M
you THATE EMBER Anothers
4
415 WANTE PSTION is WAVONG Avenues
soun wi
you INMAGE Epstoons is WALLUG Anims Con
r/45 INMATE EPITHER is sleeping
B
500 525 INMANE EPSTHEN sprom towsleep
630 NMATER /nm Gpann Espium is Appears sleep tongleep
Js
645 INMAGE Esptie- isslap
600 INMATE Epsties is sleepick
to
B
65 620 INMATE Epssion is Respect
B
630 INMAGE Enster is PACING THECOLL Is
lumpt Epsker IS using Brown j3
64/25 in rease GRSTION us.p PACICE Is
you INMATE Epssar ASKEDMO ABOUT its BREAKANT
7:15 AM I/C Albert MCDUFfie # 86768054 assumes responsibility
Inmast Bauset 76269-0521 Scyning Ors
for inmate Epstein # 76318-054 in cell#4
as
7:30 AM AM Inmate Epstein is Sitting on the bed
Inmate Epstein is pacing around the room- am
am
7:45 Inmate Erstein is talking to the psyche
7.45 Dr
Psvd voit toward by
CONFIDENTIAL
SDNY_00009
EFTA0003

=== Page 13 ===
AM
8:00 AM Inmate Epstein is sitting on the bed
am
8:15 Inmate Epstein is pacing the room
am
330 AM Inmate Epstein istaking a shower and
JE
M
8:45 AM Inmate is getting dressed for lawyer visit
He will be receiving a new set of clothes
JE
41
am
9:00 Inmate Epstein has entered a regular housing unit-am am
End of shift Albert McDuffie # 86768054
CONFIDENTIAL
SDNY_00009731
EFTA0003397


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=== Page 1 ===
To:
From:
Sent:
Tue 7/23/2019 6:56:36 PM
Subject:
Suicide Watch/Psych Observation Update
TEXT.htm
Suicide Watch
1. Epstein #76318-054
Psych Observation
None
Thank you,
CONFIDENTIAL
SDNY_00009884
EFTA00034026


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=== Page 1 ===
From:
"
)"
To:
Cc:
)"
Subject: Tova Noel
Date: Wed, 14 Aug 2019 15:02:28 +0000
Attachments: 2019.08.14_Tova_Noel_Subpoena.pdf
Mr. Foy,
Based on our phone conversation, I understand that you represent Ms. Noel and are authorized to accept service of this
subpoena on her behalf. Please see attached.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00032382


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=== Page 1 ===
FD-597 (Rev 8-11-94)
Page
of
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property Received/Returned/Released/Seized
File #
On (date) 8/10/19
item(s) listed below were:
Received From
Returned To
Released To
Seized
(Name) BUREAU OF PRISONS, METROPOLITAN CORRECTIONS CENTER
(Street Address) 150 PARK Row
(City) NEW YORK NY 01007
Description of Item(s):
1
SENGATE HARD DRIVE S/N: Z376CJJA
2
HITACHI HARD DRIVE S/V: JP1572JE36A13K
3
SEAGATE HARD DRIVE S/N: Z376CF5X
4
SEAGATE HARD DRIVE S/N: 9QM8MT9P
5
HITACHI HARD DRIVE S/N: JP1572JE6MWNK
6
SEAGATE HARD DRIVE S/N: 90M8EC75
>
SEAGATE HARD DRIVE S/N: STSOONMOOH RUH ZIMIPZPE
8
WESTERN DIGITAL HARD DRIVE S/N: WCAV97911026
9
WESTERN DIGITAL HARD DRIVE S/N: WCCZEJVC34CJ
10
SEAGATE HARD DRIVE S/N: 9QM8MSEZ
Ener
11
SEAGATE HARD DRIVE S/N: STSUUNMOON
ZIMIPX26
12
SEAGNE HARD DRIVE S/N: S7500NMOOH - ZIMI QFX
13
WESTERN DIGITAL HARD DRIVE S/N: WCAV9T870016
14
WESTERN DIGITAL HARD DRIVE S/N: WCC2E0DE83YK
15
SEAGATE HARD DRIVE S/N: 9QM8MT6D
16
SEAGATE HARD DRIVE S/N: ZIMIPZ07
17
SEAGATE HARD DRIVE S/N: ZIMILOYG
18
SEAGATE HARD DRIVE SIN: 9QM8MSRR
Received By:
(Signature)
/
(Signature)
EFTA00032095


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=== Page 1 ===
From: White Collar Law360 <news@law360.com>
To:
Subject: 5 Ways Companies Can Prep For Biden's Anti-Corruption Push
Date: Thu, 17 Jun 2021 07:35:33 +0000
Law360 White
Collar
WHITE COLLAR
Thursday, June 17, 2021
Follow Law360
TOP NEWS
Law360 Rising Stars 2021
Analysis
5 Ways Companies Can Prep For Biden's Anti-Corruption Push
With President Joe Biden gung-ho about fighting corruption, new anti-money
laundering rules looming, and vulnerabilities that were amplified by
the pandemic, companies should act now to reexamine and bolster their
compliance programs, experts say.
Read full article
Robbins Geller Wants To Fight FIFA Suit DQ At 2nd Circ.
Robbins Geller Rudman & Dowd LLP has asked a New York federal judge to
give the firm time to appeal his ruling that it committed fraud worthy of
disqualification by failing to disclose short positions held by the lead plaintiff
in a securities class action stemming from the FIFA corruption scandal, a
request the defendant company said comes way too late.
LAW FIRMS
2 documents attached Read full article
Aidala Bertuna
Greenberg Traurig's NY Bill May Aid Russian Oligarch Client
Akin Gump
Arent Fox
Greenberg Traurig successfully lobbied for a New York state bill that will
make it harder to enforce foreign judgments, which could be worth $700
Arnold & Porter
million or more to a Vladimir Putin-linked Russian oligarch who is a client of
BakerHostetler
the firm. The state senator who sponsored the bill had no idea.
Ballard Spahr
Letter attached Read full article
Blackstone Chambers
Blank Rome
Ex-Goldman Exec's Virus-Delayed 1MDB Trial Set For January
Bracewell LLP
Former Goldman Sachs managing director Roger Ng will face trial in January
Brafman & Associates
over his purported role in the 1Malaysia Development Berhad scandal, a
Cadwalader Wickersham
New York federal judge said Tuesday, rescheduling the proceeding after a
pandemic-related delay.
Clarence Dyer
Read full article
Cloth Fair Chambers
Clyde & Co
ENRC Adviser Regrets Lying In SFO Tipoff About Dechert Atty
Cohen & Gresser
A former ENRC security consultant testified on Wednesday that he regretted
Cohen Milstein
lying in an anonymous letter he sent to the Serious Fraud Office accusing a
Dechert attorney investigating alleged corruption at the Kazakh mining
Conrad & Metlitzky
company of colluding with the agency's officials.
Constantine Cannon
Read full article
Cravath Swaine
Crowell & Moring
NYC Bar Wants Arrest Question On Bar Application Amended
DLA Piper
The New York City Bar Association has urged the New York state court
Davis Polk
system not to ask state bar applicants about their involvement with the
Davis Wright Tremaine
EFTA00032732

=== Page 2 ===
juvenile justice system or criminal cases that were sealed, adjourned or
Dechert
dismissed.
Derek Smith Law Group
Read full article
Dinsmore & Shohl
Ex-Cognizant Execs Want Cooperator's Bribery Probe Docs
Ellsworth Law Firm
Two former Cognizant Technology Solutions Corp. executives charged with
Erskine Chambers
foreign bribery are seeking to force an Indian conglomerate to hand over
information that could help clear their names, arguing that a New Jersey
Essex Court Chambers
federal court has jurisdiction over the conglomerate because it cooperated
Faegre Drinker
with U.S. investigators.
Fine Kaplan
Motion attached Read full article
ForsterBoughman
Frankfurt Kurnit
Jailed Maxwell Decries 'Raw Sewage,' Nosy Guards
Freshfields
Ghislaine Maxwell cannot defend herself against child sex-trafficking charges
with feces raining down in her cell and federal prison guards listening in on
Friedman Kaplan
her privileged conversations, one of her attorneys told a Manhattan federal
Gateley PLC
judge in a letter Tuesday.
Gelb & Gelb
Letter attached Read full article
Gibbons PC
Girardi & Keese
Ex-NASA Chief Gets 30 Days For Hiding Ties To China
Goodwin Procter
A New York federal judge on Wednesday hesitantly sentenced a NASA
Greenberg Traurig
nanotechnology pioneer to 30 days in prison for concealing his ties to the
Chinese government, pointing out that defendants with lesser bona fides are
Haddon Morgan
routinely locked up for lying to the government.
Hagens Berman
2 documents attached Read full article
Hogan Lovells
Holland & Knight
COMPLIANCE
Iredale & Yoo
Jomarron Lopez
Ex-City National VP Says He Was Fired For Tax Whistleblowing
Jones Day
A former senior vice president for the Royal Bank of Canada's U.S.
subsidiary City National Bank sued his ex-employer in California federal
King & Siegel
court, claiming he was wrongfully fired because he raised concerns about
Krieger Kim
possible tax fraud and misconduct.
Lathrop GPM
Complaint attached Read full article
Law Office of John D. Cline
Levene Neale
SECURITIES
Lowenstein Sandler
Trader Pushes Back Against Witness In Illumina Insider Trial
Margulies Faith
Mayer Brown
Counsel for a San Diego stock speculator accused of insider trading worked
Wednesday to undermine the credibility of a former Illumina Inc. accountant
McDermott Will
who told a Manhattan jury she tipped him to earnings secrets in exchange for
Milbank LLP
envelopes stuffed with cash.
Moses & Singer
Read full article
Neal R. Sonnett PA
Nelson Mullins
6 Members Of $1.7M Tech Insider Trading Ring Get Pinned
Norton Rose
Three members of an alleged $1.7 million insider trading ring were hit with
criminal charges Tuesday, while much of the ring settled claims lobbed by the
One Essex Court
U.S. Securities and Exchange Commission that they traded off of material
Orrick Herrington
nonpublic information on two technology companies.
Paul Weiss
4 documents attached Read full article
Perkins Coie
Post & Schell
PUBLIC INTEGRITY
Quinn Emanuel
Robbins Geller
Former Boston Cop 4th To Admit Stealing oT Pay
A retired Boston cop detailed to the department's evidence warehouse
Ropes & Gray
admitted Wednesday to embezzling more than $36,000 from the city by filing
Scharf Banks
for overtime hours she never worked, becoming the fourth officer to plead
Selendy & Gay
guilty in the scheme.
Skadden Arps
Read full article
Squire Patton
EFTA00032733

=== Page 3 ===
INTELLECTUAL PROPERTY
Stroock & Stroock
Swanson & McNamara
GSK Denied Restitution In Trade Secrets Theft Case
Three Raymond Buildings
A Pennsylvania federal judge said Monday that GlaxoSmithKline LLC is not
Vorys Sater
entitled to recoup fees and costs incurred by outside counsel from DLA Piper
as part of a criminal case over trade secrets stolen from the company.
Wachtell Lipton
WilmerHale
Opinion attached Read full article
COMPANIES
ENVIRONMENTAL
1-800 Contacts Inc.
Feds Say No To Vacating Guilty Plea In $42M Pollution Case
7-Eleven Inc.
Government prosecutors urged a Pennsylvania federal judge to reject a
Amalgamated Transit Union
contractor's bid to withdraw his guilty plea, arguing there was no difference or
Amazon.com Inc.
conflict of interest between him and his company when he copped to
American Bar Association
dumping pollutants in the Susquehanna River during a bridge restoration
Apple Inc.
project.
Chevron Corp.
Brief attached Read full article
City National Bank
APPELLATE
Cognizant Technology Solutions
Corp.
1st Circ. OKs Hefty Prison Term For Lottery, Emerald Hoaxes
Equal Justice Initiative
The First Circuit on Tuesday upheld the conviction and 13-year prison
Facebook Inc.
sentence for an Ohio man who sweet-talked victims into parting with their
Federation Internationale de
retirement savings and other investments with colorful schemes about uncut
Football Association
emeralds and vast lottery winnings frozen in a New York bank account.
Fortinet Inc.
Opinion attached Read full article
George Washington University
Georgetown University
HEALTH
Google LLC
Analysis
Grupo Televisa SAB
Escobar 5 Years Later: How FCA Earthquake Is Reverberating
Humana Inc.
Five years ago Wednesday, the U.S. Supreme Court addressed a billing
ICAP
dispute tied to one patient's treatment at a Massachusetts clinic and in the
Illumina Inc.
process rattled the nation's entire False Claims Act docket with new doctrine.
Infinera Corporation
Here, Law360 explores the landmark case's aftermath and finds a litigation
landscape that hasn't come close to stabilizing.
International Business Machines
Opinion attached Read full article
Corp.
JAMS Inc.
NYC Doc Gets Over 4½ Years For Taking Insys Kickbacks
Larsen & Toubro Ltd.
A former New York City doctor on Wednesday was sentenced to more than
London Stock Exchange Group
4½ years in prison for taking hundreds of thousands of dollars in kickbacks
PLC
from now-defunct drugmaker Insys Therapeutics Inc. in exchange for
Michelin Group
prescribing a powerful fentanyl spray to his patients.
National Association for the
Read full article
Advancement of Colored People
New York City Bar Association
Humana Claims In Telemed RICO Case Advance In Fla. Court
New York State Bar Association
A Florida federal judge has ruled that a telemedicine company and several
physicians cannot escape Humana's lawsuit accusing them of preying on its
PG&E Corp.
policyholders through a complex nationwide scheme that allegedly billed the
Porsche
insurer for millions of dollars' worth of unnecessary prescription creams.
QUALCOMM Inc.
Order attached Read full article
Royal Bank of Canada
SolarWinds Corp.
GOVERNMENT CONTRACTS
Space Exploration Technologies
Corp.
San Antonio Man Admits To Role In Air Force Fraud Scheme
The Lawyers' Committee for Civil
A former U.S. Air Force civilian employee has pled guilty to receiving more
Rights Under Law
than $2.3 million in kickbacks and bribes in return for his help in securing
Universal Health Services Inc.
EFTA00032734

=== Page 4 ===
multimillion-dollar government contracts through a fraud scheme that lasted
YouTube Inc.
more than a decade.
Zeughauser Group LLC
Read full article
TAX
GOVERNMENT AGENCIES
Consumer Financial Protection
Magistrate Assigned To Roger Stone's $2M Tax Case Recuses
Bureau
A U.S. magistrate judge assigned to Roger Stone's $2 million unpaid tax suit
Economics and Statistics
in Florida recused himself from the case Wednesday.
Administration
Order attached Read full article
Executive Office of the President
Federal Trade Commission
COMPETITION
Financial Crimes Enforcement
Network
Ex-Bumble Bee CEO Fights Antitrust Conviction At 9th Circ.
Information Commissioner's Office
Former Bumble Bee CEO Chris Lischewski urged the Ninth Circuit on
Internal Revenue Service
Wednesday to overturn his conviction for his role in an alleged tuna price-
fixing conspiracy, arguing that the trial judge gave erroneous instructions that
National Aeronautics and Space
provided jurors with too many details on antitrust law and led to his wrongful
Administration
conviction.
Serious Fraud Office
Read full article
U.S. Air Force
U.S. Attorney's Office
EXPERT ANALYSIS
U.S. Attorney's Office for the
District of Massachusetts
Law Firm Talent Must Reflect Shifting US Demographics
U.S. Attorney's Office for the
Stephanie Scharf at Scharf Banks and Roberta Liebenberg at Fine Kaplan
District of New Jersey
analyze and project U.S. demographic trends to show that law firms that
hope to succeed long-term must recruit, retain and advance female lawyers
U.S. Attorney's Office for the
Eastern District of New York
and lawyers of color, and they outline six steps for meeting these goals.
Read full article
U.S. Attorney's Office for the
Eastern District of Pennsylvania
LEGAL INDUSTRY
U.S. Attorney's Office for the
Middle District of Pennsylvania
Client Data Stolen From UK Law Firm Gateley In Cyberattack
U.S. Attorney's Office for the
Northern District of California
London law firm Gateley PLC revealed on Wednesday that it has been
targeted by a cyberattack that resulted in some of its clients' information
U.S. Attorney's Office for the
Southern District of New York
being compromised, making it the latest casualty of an online security breach
in the legal industry.
U.S. Attorney's Office for the
Read full article
Western District of Texas
U.S. Census Bureau
7 More Firms Raise Associate Salaries
U.S. Court of Appeals for the First
A host of law firms this week have moved to match Davis Polk & Wardwell
Circuit
LLP and raise U.S. associates' starting salaries, and one firm has combined
U.S. Court of Appeals for the Ninth
the announcement with a plan to accelerate its promotion track.
Circuit
Read full article
U.S. Department of Commerce
U.S. Department of Justice
Federal Claims Judge Confirmed To Md. District Court
U.S. Department of the Treasury
A bipartisan Senate vote on Wednesday confirmed a DLA Piper alum to
move from the U.S. Court of Federal Claims to a lifetime seat on Maryland's
U.S. District Court for the Central
federal district court.
District of California
Read full article
U.S. District Court for the District of
Massachusetts
Cravath Donating $6M Fee To Groups Supporting Civil Rights
U.S. District Court for the District of
Cravath Swaine & Moore LLP announced on Tuesday it will donate $6 million
New Jersey
it earned in attorney fees in pro bono work to five national and local Alabama
U.S. District Court for the Eastern
organizations supporting civil rights and diversity efforts.
District of New York
Read full article
U.S. District Court for the Eastern
District of Pennsylvania
Dechert Hit With Discrimination Suit By Ex-Billing Manager
U.S. District Court for the Middle
District of Pennsylvania
EFTA00032735

=== Page 5 ===
A former billing manager at Dechert LLP said her supervisor created a hostile
U.S. District Court for the Northern
work environment and set impossibly high standards for her because she
District of California
was Black, according to a racial discrimination lawsuit she filed against the
U.S. District Court for the Southern
firm in Pennsylvania federal court Wednesday.
District of Florida
Read full article
U.S. District Court for the Southern
Girardi's Ex-Clients Go After His Wife In State Malpractice Suit
District of New York
Former clients of celebrity trial lawyer Thomas V. Girardi, along with the
U.S. District Court for the Western
bankruptcy trustee liquidating the embattled attorney's personal property,
District of Texas
have urged a California bankruptcy judge to lift a stay so the ex-clients can
continue their collection pursuit against his estranged wife, "Real Housewives
U.S. Patent and Trademark Office
of Beverly Hills" star Erika Girardi.
U.S. Securities and Exchange
Read full article
Commission
U.S. Senate
Analysis
U.S. Supreme Court
Khan Goes From Commissioner To Chair In Under 6 Hours
U.S. Uniform Law Commission
In a single afternoon, Lina Khan was confirmed to the Federal Trade
Commission, sworn in, and made its chair in a surprise move that sets up the
Big Tech critic for a role she was not anticipated to play and has left
observers wondering what to expect.
Read full article
Marshals Need More Staff To Protect Judges, DOJ Report Says
Less than a year after the killing of a New Jersey federal judge's son by an
angry male rights attorney, a U.S. Department of Justice audit found that the
U.S. Marshals Service is understaffed and not properly equipped to protect
the judiciary.
Read full article
Ex-Orrick Atty Now 'Supreme Court Director' At Georgetown
Georgetown Law's Institute for Constitutional Advocacy and Protection has
named former Orrick partner Kelsi Brown Corkran as its first U.S. Supreme
Court director, a role in which she will manage the group's litigation strategy
for civil rights and criminal justice in the nation's top court.
Read full article
NY DAs Urge Gov. Cuomo To Veto Conduct Commission Bill
An association that represents New York state prosecutors urged Gov.
Andrew Cuomo to veto a recently passed bill that would create an oversight
body to investigate prosecutorial misconduct complaints, saying that the
commission would delay and interfere with attorney discipline.
Read full article
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EFTA00032737


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: protective order and draft affidavit
Date: Tue, 28 Jul 2020 19:29:05 +0000
Attachments: 2020-07-27_GM_letter_to_Judge_Nathan_re_protective_order_updated.ebd.docx
From:
Sent: Tuesday, July 28, 2020 3:04 PM
To:
(USANYS)
is
(USANYS)
Cc:
>;
Subject: protective order and draft affidavit
As promised. I've never done one of these affidavits before, so very happy for any suggestions on that in particular.
EFTA00031993


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=== Page 1 ===
Cc:
To:
From:
Sent:
Tue 7/23/2019 12:55:47 PM
Subject: Inmate Epstein #76318-054 (Suicide Watch)
TEXT.htm
The Inmate Companion called and reported that inmate Epstein said his throat is swollen.
Thanks,
CONFIDENTIAL
SDNY_00009874
EFTA00034021


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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com>
To:
Subject: Foul With Routine Witness Trips Up Deutsche Libor Trial
Date: Mon, 01 Oct 2018 07:40:09 +0000
Law360 White
Collar
WHITE COLLAR
Monday, October 1, 2018
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
Foul With Routine Witness Trips Up Deutsche Libor Trial
The government's Libor-rigging case against two former Deutsche Bank
traders has suffered setbacks in recent days, after a routine witness put on to
authenticate documents admitted signing an untrue declaration, which led to
harsh words from a federal judge to prosecutors and the exclusion of a swath
of trading data from coming into the case. Read full article
Musk To Pay $20M In Settlement Over Going-Private Tweets
Elon Musk has agreed to step down as chairman of Tesla Inc. and pay a $20
million fine as part of settlements unveiled by the U.S. Securities and
Exchange Commission on Saturday, two days after the agency sued Musk
for allegedly having posted misleading Twitter messages about taking Tesla
Listen to our new podcast here
private. Read full article
Dems' Emoluments Suit Not Just A Political Fight, Judge Says
LAW FIRMS
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With D.C. Circuit Judge Brett Kavanaugh's fate as the ninth justice
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new term Monday without a case of blockbuster proportions. But
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there are several bread-and-butter business issues filling out the
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Kirkland & Ellis
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liability in securities fraud actions and a case that could undo how
Latham & Watkins
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The U.S. Securities and Exchange Commission announced Friday that the
former vice president of servicing at Ocwen Financial Corp. has agreed to
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Ex-Texas Pol Charged With Fraud Over Frack Sand Scheme
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Orrick Herrington
The U.S. Securities and Exchange Commission on Friday announced it has
charged a former Texas state senator and another man over a scheme that
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raised millions from investors for a hydraulic fracking-related company based
Perkins Coie
on misrepresentations. Read full article »
Polsinelli
Proskauer Rose
CFTC Starts Insider Trading Task Force, Sues Energy Trader
Quinn Emanuel
The Commodity Futures Trading Commission announced Friday that it has
created an insider trading task force, the same day the agency accused a
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Houston-based energy commodities trader of using clients' trading
Robins Kaplan
information to help a friend make money. Read full article
Seyferth Blumenthal
IT Exec Gets 3 Years For Role In $2.8M Fraud Scheme
Sidley Austin
Skadden
A former Illinois information technology firm executive was sentenced Friday
to 39 months in prison for taking part in a scheme to steal more than $2.8
Sterne Kessler
million from the company. Read full article
Sullivan & Cromwell
Troutman Sanders
FCPA
Vinson & Elkins
Stryker Settles SEC's Latest FCPA Claims For $7.8M
Williams & Connolly
Medical device company Stryker Corp. agreed to pay a $7.8 million penalty
Winston & Strawn
over accounting and record keeping failures in China, India and Kuwait,
marking the company's second settlement with the U.S. Securities and
COMPANIES
Exchange Commission over Foreign Corrupt Practices Act violations. Read
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full article »
AT&T Inc.
Abercrombie & Fitch
LEGAL ETHICS
Altisource Portfolio Solutions SA
NJ Atty Cops To Role In Short-Sale Mortgage Fraud
Amazon.com Inc.
A New Jersey attorney on Friday copped to his role in a large-scale mortgage
American Bar Association
fraud scheme that involved properties in Jersey City, Clifton, Union and
American Standard
elsewhere and caused losses of millions of dollars, federal prosecutors
Apple Inc.
announced. Read full article
Avaya Inc.
HEALTH
Bank of America Corporation
Bayer AG
Opioid Task Force Arrests 76 After Raid On Tribal Land
CONCACAF
The U.S. Department of the Interior has announced 76 drug-related arrests
Charter Communications Inc.
following a department-led undercover operation on North Carolina tribal
Coinbase Inc.
lands, marking the latest development in a federal initiative created to combat
the opioid crisis in Native American communities. Read full article »
Deutsche Bank AG
Fannie Mae
SPORTS
Federation Internationale de
Football Association
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Prosecutors Want $55M Restitution For Soccer Bribe Convicts
Golden State Warriors
Federal prosecutors have told a New York federal court that two South
Google Inc.
American soccer bosses convicted of bribery-related charges as part of the
HSN, Inc.
wider FIFA corruption investigation should pay their victims nearly $55 million
Helsinn Healthcare SA
in restitution, plus a percentage of their salaries and some investigation
costs. Read full article
Henry Schein Inc.
Intercontinental Exchange Inc.
LEGAL INDUSTRY
JPMorgan Chase & Co.
Janus Henderson Group PLC
Feature
Up Next At High Court: Justices Kick Off Term Short-Staffed
Merck & Co Inc.
The U.S. Supreme Court will be one member short when it comes in session
Monsanto Co.
Monday morning to hear a handful of cases being closely followed by
Morgan Stanley
environmental and employment lawyers after sexual assault claims derailed
NBCUniversal Inc.
D.C. Circuit Judge Brett Kavanaugh's hopes for a speedy confirmation. Read
full article
NFL Enterprises LLC
National Basketball Association
FBI Investigating Kavanaugh Allegations After Panel Vote
Nestle
The FBI over the weekend started an investigation into the allegations of
Oakland Raiders
sexual assault against D.C. Circuit Judge Brett Kavanaugh, following a
Ocwen Financial Corporation
Senate Judiciary Committee vote Friday that advanced his Supreme Court
nomination to the full Senate. Read full article
PHH Corporation
Panasonic Corporation
Feature
PepsiCo Inc.
Rocket-er Docket: Mass. IP Case Sees 2 Trials In 6 Months
Petrobras
Court watchers have been left marveling at the rapid pace of an intellectual
Pfizer Inc.
property dispute between a pair of Massachusetts 3D printing rivals, which
raced to trial in less than four months this summer and saw a second trial
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between the two end Thursday. Read full article
Platinum Partners LP
Prime Inc.
Calif. High Court Approves Updates To State Bar Rules
Robert Half International Inc.
The California Supreme Court on Friday approved a final version of its new
SBM Offshore NV
Rules of Professional Conduct, which are set to go into effect in November,
including a major update to a provision governing how attorneys can counsel
Scientific Games Corp.
clients regarding potentially criminal activity. Read full article
State Bar of California
Stolt-Nielsen SA
Manatt Can't Dodge Recruiter's $335K Trial Win, Panel Says
Stryker Corp.
A California appeals court on Friday affirmed a jury's finding that Manatt
Phelps & Phillips LLP must pay a legal recruiter $335,000 for connecting the
Tampa Bay Buccaneers
firm with its managing partner-elect, ruling that substantial evidence backed
Teva Pharmaceutical Industries
the jury's verdict. Read full article
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Ex-King & Spalding Atty Aims To Block Lawyer's Lien Bid
Trump Organization Inc.
A former King & Spalding LLP associate, who has accused the firm of ousting
Tween Brands Inc.
him after he aired ethical concerns, said in a brief filed Friday in New York
federal court that his onetime attorney has no right to a piece of any future
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settlement, asserting that the attorney cannot show good cause for his
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Ex-Armstrong Teasdale Atty Wants Bias Suit Revived
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A former Armstrong Teasdale LLP partner has asked the Eighth Circuit to
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revive his Missouri federal age bias suit against the firm, arguing a ruling that
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ended an earlier state suit shouldn't block his claims under the federal Age
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GOVERNMENT AGENCIES
Law Schools Need Admission Overhaul For Diversity: Report
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A research and policy institute that focuses on legal education has unveiled a
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new report that recommends concrete changes law schools can make in
Commodity Futures Trading
order to help diversify the still disproportionately white legal industry, saying
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that law schools currently contribute to the profession's overall lack of racial
diversity. Read full article
Consumer Financial Protection
Bureau
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=== Page 4 ===
Feature
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growing circuit split on whether federal anti-discrimination law protects gay
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and transgender workers. Read full article »
Food and Drug Administration
Feature
Securities and Exchange
Commission
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New York Stock Exchange owner Intercontinental Exchange Inc. tapped a
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former McKenna Long & Aldridge LLP attorney as its next general counsel,
U.S. Census Bureau
and the new Fox company has picked a Kirkland & Ellis LLP partner to be its
U.S. Department of Health and
legal boss. Here, Law360 looks at some of September's top in-house hires
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and promotions. Read full article »
U.S. Department of Justice
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For those who missed out, here's a look back at the law firms, stories and
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All eyes were on Capitol Hill this week for a pivotal hearing on Dr. Christine
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Blasey Ford's allegations of sexual assault against U.S. Supreme Court
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nominee Brett Kavanaugh. On this week's Pro Say podcast, we unpack the
whole chaotic week of news. Read full article
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Epstein calls
Date: Thu, 29 Aug 2019 14:52:36 +0000
No problem-thanks very much for checking!
From:
Sent: Thursday, August 29, 2019 10:51 AM
To:
Subject: RE: Epstein calls
Sorry
From:
Sent: Thursday, August 29, 2019 10:47 AM
To:
Subject: RE: Epstein calls
Thanks
I had not received these. Will pass along to the rest of the team.
From:
Sent: Thursday, August 29, 2019 10:01 AM
To:
Subject: Epstein calls
I just want to be sure that you received all of these previous calls.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS) 6"
Subject: RE: sec
Date: Fri, 16 Aug 2019 13:36:39 +0000
Love it
Original Message
From:
(USANYS)
Sent: Friday, August 16, 2019 9:26 AM
To:
(USANYS)
Cc:
(USANYS)
(USANYS) 6
Subject: Re: sec
Dude, I started my email by apologizing for the ping!
The SEC's failure to register as an IA case most continue!
Thx
Sent from my iPhone
> On Aug 16, 2019, at 9:23 AM,
(USANYS)
wrote:
>
> This fell down the priority list after, you know, he strangled himself the morning after our call. But
may
have spoken to the team about it? If not we'll try to today.
V
> Sent from my iPhone
V
On Aug 16, 2019, at 9:19 AM,
(USANYS)
wrote:
Guys,
Sorry for the ping on this, but Sec called me about Epstein stuff. I think where we left off is you were going
to confirm that you hadn't seen anything in the records consistent with him investing other people's money.
>>
Sent from my iPhone
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=== Page 1 ===
To:
From:
Sent:
Mon 8/12/2019 7:31:47 PM
Subject: Psych Observation 7/24-30/19 (I/M companion utilized) re: Epstein, Jeffrey Edward, Reg. No.
73618-054
TEXT.htm
2019 08 12 15 15 46.pdf
Charisma Edge.vcf
Psych Observation 7/24-30/19 (I/M companion utilized)
CONFIDENTIAL
SDNY_00009597
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=== Page 1 ===
To:
From:
Sent:
Mon 8/12/2019 7:36:31 PM
Subject: Fwd: SW Chronological Log 7/23-24/19 re: Epstein, Jeffrey Edward, Reg. No. 73618-054
TEXT.htm
SW Chronological Log 7/23-24/19 re: Epstein, Jeffrey Edward, Reg. No. 73618-054
SW Chronological Log 7/23-24/19 re: Epstein, Jeffrey Edward, Reg. No. 73618-054
.vcf
I forgot to CC you.
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
CONFIDENTIAL
SDNY_00009678
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=== Page 1 ===
U.S. V. Neill, 952 F.Supp. 834 (1997)
Interference in Attorney-Client Relationship
KeyCite Yellow Flag - Negative Treatment
For purposes of constitutional violation arising
Declined to Follow by U.S. V. Taylor, D.Me., February 9, 2011
out of government's intrusion upon
952 F.Supp. 834
attorney-client privilege, it matters little whether
United States District Court,
intrusion occurred prior to initiation of formal
District of Columbia.
adversary proceedings, inasmuch as right to fair
trial may be crippled by government
UNITED STATES of America
interference with attorney-client privilege long
V.
before formal commencement of criminal
Denis M. NEILL, James P. Neill, Defendants.
proceeding. U.S.C.A. Const.Amend. 6.
Crim. Action No. 95-0323 (JHG).
1 Cases that cite this headnote
Jan. 17, 1997.
Synopsis
[3]
Criminal Law
Defendants charged with tax offenses moved to dismiss
Interference in Attorney-Client Relationship
due to government's invasion of their attorney-client
privilege. Government opposed motion. The District
Court, Joyce Hens Green, J., held that: (1) government's
Not every government intrusion on
attorney-client privilege is constitutional
affirmative decision to invoke "taint team" procedures
violation. U.S.C.A. Const.Amend. 6.
with regard to handling potentially privileged documents
was per se intentional intrusion upon defendants'
attorney-client privilege, but (2) government successfully
3 Cases that cite this headnote
rebutted presumption of harm arising from its decision to
use "taint team" procedures.
Motion to dismiss denied; motion to supplement record
denied.
[4]
Criminal Law
Consultation with Counsel; Privacy
When government agents acquire information
subject to attorney-client privilege, but do not
West Headnotes (14)
communicate that information to prosecutors,
there is no violation of accused's rights to fair
trial and effective assistance of counsel.
[I]
Criminal Law
U.S.C.A. Const.Amend. 6.
Interference in Attorney-Client Relationship
Substantial questions of fundamental fairness
Cases that cite this headnote
are raised when, in connection with criminal
prosecution, government invades accused's
attorney-client
privilege.
U.S.C.A.
Const.Amend. 6.
[5]
Criminal Law
Interference in Attorney-Client Relationship
1 Cases that cite this headnote
Although there is presumption that information
subject to attorney-client privilege obtained by
government agents is conveyed to prosecution
team, government may rebut that presumption
[2]
Criminal Law
WESTLAW © 2018 Thomson Reuters. No claim to original U.S. Government Works.
1
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=== Page 2 ===
U.S. V. Neill, 952 F.Supp. 834 (1997)
by showing existence of suitable safeguards or
rebut presumption that tainted material was
by demonstrating that there will be no prejudice
provided to prosecution team. U.S.C.A.
to defendants as result of these communications.
Const.Amend. 6.
U.S.C.A. Const.Amend. 6.
11 Cases that cite this headnote
2 Cases that cite this headnote
[9]
Criminal Law
[6]
Criminal Law
Interference in Attorney-Client Relationship
Sanctions for Breach of Prosecutorial Duties
Government successfully rebutted presumption
There must be substantial demonstration of
of harm arising from its decision to use "taint
prejudice before indictment can be dismissed
team" procedures in handling information
based on government's intrusion upon accused's
potentially subject to attorney-client privilege,
attorney-client
privilege.
U.S.C.A.
rather than submitting disputed materials for in
Const.Amend. 6.
camera review by court, in that government took
precautions to shield prosecution team from
viewing potentially privileged materials during
Cases that cite this headnote
execution of search warrant, prosecution team
witnesses testified that they received no
privileged information from agents exposed to
potentially privileged materials, taint team took
sufficient precautions to ensure that prosecution
[7]
Criminal Law
did not have access to potentially privileged
Interference in Attorney-Client Relationship
documents or become aware of those materials'
contents, prosecution team member sealed,
Government's affirmative decision to invoke
without reading, and delivered to taint team
"taint team" procedures with regard to handling
potentially privileged materials he accidentally
documents potentially subject to attorney-client
discovered, and no evidence indicated that
privilege, rather than follow more traditional
government acquired defendants' trial theories
approach of submitting contested materials for
or strategies. U.S.C.A. Const.Amend. 6.
in camera review by magistrate, was per se
intentional intrusion upon privilege. U.S.C.A.
Const.Amend. 6.
12 Cases that cite this headnote
5 Cases that cite this headnote
[10]
Criminal Law
Interference in Attorney-Client Relationship
[8]
Criminal Law
Although factual disclosures obtained through
Effect of Representation or Deprivation of
invasion of attorney-client privilege that enable
Rights
government to better investigate its case could
rise to level of Sixth Amendment violation if
When government chooses to take matters into
substantial, disclosure of facts is presumptively
its own hands with regard to handling of
less harmful than disclosure of trial strategy.
information potentially subject to attorney-client
U.S.C.A. Const.Amend. 6.
privilege, rather than using more traditional
alternatives of submitting disputed documents
under seal for in camera review by neutral and
1 Cases that cite this headnote
detached magistrate or by court-appointed
special masters, government bears burden to
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2
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=== Page 3 ===
U.S. V. Neill, 952 F.Supp. 834 (1997)
[14]
Criminal Law
Amendment and Correction
[II]
Criminal Law
Particular Cases in General
Order granting government's request to
Criminal Law
supplement the record, with regard to
Miscellaneous Particular Issues
defendants' motion to dismiss on ground that
government intruded upon attorney-client
Disclosure to prosecution team of identity of
privilege, did not provide equitable basis for
person associated with defendant, as result of
granting defendants' motion to supplement the
team member's inadvertent discovery of
record, inasmuch as defendants did not object to
document protected by attorney-client privilege,
government's request and document admitted
did not violate defendant's rights to fair trial and
pursuant to order had already been provided to
effective assistance of counsel. U.S.C.A.
court with other documents submitted for in
Const.Amend. 6.
camera review, based on defendants' request,
and therefore order merely ensured that
document was available to defendants.
2 Cases that cite this headnote
Cases that cite this headnote
[12]
Criminal Law
Sanctions for Breach of Prosecutorial Duties
Defendants were not entitled to dismissal on
Attorneys and Law Firms
ground that government improperly intruded
upon attorney-client privilege by examining
*836 John Martin Bray and Joseph Martin Jones,
seized computer files when defendants failed to
Schwalb, Donnenfeld, Bray & Silbert, P.C., Washington,
assert privilege with respect to those materials.
DC, for Denis M. Neill.
U.S.C.A. Const.Amend. 6.
Charles Taylor Smith, II, Ober, Kaler, Grimes & Shriver,
Baltimore, MD, Martha Purcell Rogers and Hartman E.
Cases that cite this headnote
Blanchard, Ober, Kaler, Grimes & Shriver, Washington,
DC, for James P. Neill.
Richard A. Poole, U.S. Department of Justice, Criminal
Division, Fraud Section and John E. Sullivan, U.S.
[13]
Privileged Communications and
Department of Justice, Criminal Section, Tax Division,
Confidentiality
Washington, DC, for the U.S.
Objections; Claim of Privilege
Privileged Communications and
Opinion
Confidentiality
Presumptions and Burden of Proof
MEMORANDUM OPINION AND ORDER
Proponent of attorney-client privilege bears
burden to establish its existence, and, absent
timely assertion of privilege for each specific
JOYCE HENS GREEN, District Judge.
communication or document, no privilege will
be recognized.
Pending before the Court is the defendants' Motion to
Dismiss due to the Government's Invasion of Their
Attorney-Client Privilege ("Motion to Dismiss"). After
1 Cases that cite this headnote
determining that the defendants had made the requisite
preliminary showing under United States V. Kelly, 790
F.2d 130, 137 (D.C.Cir.1986), the Court ordered an
evidentiary hearing on this issue. See United States V.
WESTLAW © 2018 Thomson Reuters. No claim to original U.S. Government Works.
3
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=== Page 4 ===
U.S. V. Neill, 952 F.Supp. 834 (1997)
Neill, Memorandum Op. at 21 & 24 (JHG) (D.D.C. Oct.
selected the latter. The PLA then reviewed each document
10, 1996). Upon consideration of the evidence introduced
for which counsel claimed privilege, seizing some and
and testimony offered at the evidentiary hearing, in light
returning others to counsel. At the offices of Neill &
of the credibility and demeanor of the witnesses, as well
Company, without reviewing the potentially privileged
as the in camera submissions offered by both parties,¹
materials in James Neill's seized briefcase, the PLA
their post-hearing briefs and the entire record in this
sealed those materials. At no time did the defendants'
matter, the Motion to Dismiss will be denied.
counsel seek judicial intervention or file a motion for a
protective order. Nor did counsel ever file a motion under
Fed.R.Crim.P.41(e).
Because materials asserted to be subject to the
I. Findings of Fact
attorney-client privilege had been seized, on October
28th, Deputy Chief of the Fraud Section Peter Clark
On October 27, 1993, federal agents executed four search
directed trial attorney Elisabethanne Stevens and her
warrants at the office of Neill and Company, and the
supervisor, Barbara Corprew, to review those materials.
homes of Defendants James and Denis Neill. On October
Stevens and Corprew formed what the Department of
28th, a fifth warrant was executed to search Defendant
Justice called a "taint team," meaning that their actions
James Neill's safe deposit box at Columbia First Bank in
would be "walled off" from the prosecution team thereby
Washington, D.C. See Mem.Op. at 1-5. Approximately
ensuring that the prosecution team remained free of the
sixty boxes of materials were seized, including
"taint" arising from exposure to potentially privileged
computers, computer files and data. Id. at 6. The seized
material. Stevens and Corprew's mandate was to review
items were stored in a locked space at the IRS Office, 500
documents for which the defendants claimed
N. Capitol St., N.E., Washington, D.C.
attorney-client privilege, determine whether the
crime-fraud exception might be applicable, and, if
While the affidavits to the search warrants and the search
necessary, litigate the existence of the privilege or the
execution memorandum stated that the federal agents
application of the crime-fraud exception.4 On October
were not to seize documents on the letterhead of the
29th, before he met with the defendants' counsel,
defendants' attorneys, these "letterhead documents" were
prosecutor Richard Poole (Senior Trial Attorney, Fraud
in fact seized over the oral and written objections of the
Section) was advised that Ms. Stevens would act in this
defendants. The agents also seized other documents that
capacity.
were not "letterhead documents" but some of which were
later claimed to be protected by attorney-client privilege.
On November 1, 1993, the defendants' counsel met with
Poole to voice their objections to the seizure of materials
In that the search warrants authorized the search of a law
for which they claimed privilege and to demand the return
office as well as the home of "837 Denis Neill, a lawyer,
of the same.5 While the defendants' counsel contend that
the government provided measures to minimize the
the government promised to return without review any
potential intrusion upon the attorney-client privilege. FBI
documents seized contrary to the search affidavits and
agent attorneys were directed to serve as Principal Legal
Search Execution Memorandum, Poole recalled telling
Advisers ("PLA's") on site to review all potentially
counsel that such documents would be returned, but only
privileged documents prior to seizure. See Mem.Op. at 6
after review by someone other than a "prosecution team"
(quoting Search Execution Memorandum of Oct. 19,
member: "We discussed the fact that the fraud section had
1993). The Search Execution Memorandum provided that
identified a review team who would be looking at the
"search team members, with the advice of PLA's as
issues raised by the claims of privilege and
appropriate, should segregate and place in sealed
would-would be responsible for resolving them,
envelopes or separate boxes, items that may be subject to
including litigation." Hearing Transcript ("Transcript") at
the attorney-client privilege. This includes any items
74 (Vol. I-B).6
which occupants of the search locations claim are
privileged." Id. (quoting Search Execution Mem. at 2).
In a follow-up letter, the defendants' counsel requested
the return of thirteen items, none of which they claimed
The seizure of potentially privileged documents was
were privileged but which were of a personal nature to the
handled differently at different search sites. At Denis
defendants or their family. See Joseph *838 Jones' letter
Neill's home, after offering Denis Neill's counsel the
of Nov. 4, 1993, at 1-2, Defendants' Exhibit ("DE") # 5.
option of sealing the materials for off-site review or of
The letter also stated:
having the PLA conduct an immediate on-site review in
With regard to the privileged items,
counsel's presence, counsel (over standing objection)
we propose to designate someone
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U.S. V. Neill, 952 F.Supp. 834 (1997)
from our office to immediately
what he may have gleaned of its content or even the fact
review these items with Attorney
of its existence. See Transcript at 86 (Vol. I-B). The
Elisabeth (sic) Stevens of your
document was later returned to the defendants by Stevens.
office in order to segregate those
items which were clearly seized in
Another set of potentially privileged materials was
contravention of your instructions
discovered by Fort on or about January 24, 1994. Fort
to seize no correspondence,
testified that while again reviewing documents that had
memoranda, etc., emanating from
already been inspected and inventoried by defense
our offices or those of James
counsel, he opened a manila envelope for Federal City
Neill's counsel, Martha P. Rogers,
National Bank which included documents that were
Esq. There may be other materials
labeled as "attorney/client privileged." See Transcript at
which
are
privileged
87 (Vol. I-B). Fort testified that he did not *839 show the
communications between Denis or
documents to anyone or read them. See id. at 87-88 &
James Neill as clients, and others
101. Instead, he immediately sealed them and then gave
(sic) attorneys." Id. at 2.7
the sealed materials to Brown, who delivered them to
Stevens. See Transcript at 101 (Vol. I-B); Transcript at
On November 2nd, Stevens received two boxes which
84-86 (Vol. II-B).
included materials that the defendants claimed were
protected by the attorney-client privilege. While
Eventually, all of the documents for which the defendants
Defendant Denis Neill's counsel did not designate anyone
asserted attorney-client privilege were returned to their
pursuant to his letter of November 4th until approximately
counsel. It is undisputed that Stevens and Corprew read
one month later, Stevens was contacted directly by
those materials. However, neither the evidence at the
Defendant James Neill's counsel, Martha Rogers, on
hearing nor the in camera submission of over two boxes
November 3, 1993. Rogers demanded the return of the
of electronic mail messages and other documents indicate
materials in James Neill's briefcase. She testified that she
that any privileged information flowed from the taint team
was advised by Stevens that such materials would be
to the prosecution team. Instead, the record and in camera
returned without review as soon as they were located.
materials reflect that Stevens and Corprew clearly
However, Stevens testified that on or about November
appreciated the need for isolating their review from the
8th, she advised Rogers that she would be reviewing those
prosecution and took steps on numerous occasions to
documents before she could make a determination
ensure that the substantive information in potentially
whether they should be returned. Still, the defendants
privileged documents was protected. Only those materials
made no request for judicial intervention.
for which attorney-client privilege was not asserted were
released to the prosecution team, and the record
During the course of the next several months, Stevens and
demonstrates that this was done only after the defendants
Corprew reviewed the initial delivery of potentially
were provided notice and an opportunity to claim
privileged materials as well as other potentially privileged
privilege.
documents later discovered among the seized items. In
two instances, IRS Special Agent Fort, a member of the
In the course of their assignment, Stevens and Corprew
prosecution team, discovered documents that were
did not review the potentially privileged data that was
marked "attorney-client" privilege among the seized
stored electronically. Unlike the letterhead documents and
items. Fort testified that, on or about December 1, 1993,
other materials that were seized, however, there is no
after one of the defendants' counsel had reviewed the
evidence demonstrating that the defendants ever asserted
seized materials and made an inventory, see Transcript at
a claim of attorney-client privilege with respect to the
83 & 104 (Vol. I-B), he began reviewing the materials.
computer material. See, e.g., Transcript at 107-08 (Vol.
While going through a three-ring binder, he happened
II-B). Nevertheless, in May and June of 1996, the
upon a tab that was labeled "Earl Glock-Attorney/Client."
government established a computer "taint team." It
After opening the notebook to the tab, he discovered what
assigned Agent Ray Smith to download the files and
appeared to him to be a legal opinion. He then removed
Agent Harvey Barlow to review them for materials that
that section, without reading the potentially privileged
were potentially privileged. See Government's
material, sealed the document and delivered it to Stevens.
Supplemental Submission Regarding Issues Arising from
See Transcript at 80-86 (Vol. I-B). Agent Brown, who
the Search Warrants, at App. 2. Potentially privileged
was present when Fort discovered and sealed the
materials were deleted from the files prior to providing
document, corroborated Fort's testimony. See Transcript
the prosecution team with computer disks containing the
at 84-85 (Vol. II-B). Fort testified persuasively that he
seized electronic files. While it is undisputed that the
neither showed the document to Poole nor did he discuss
prosecution team had access to the computers and
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U.S. V. Neill, 952 F.Supp. 834 (1997)
electronic files, the agents testified persuasively that they
Where government agents acquire privileged information,
did not access those files, and there is no evidence to the
but do not communicate that information to the
contrary. Significantly, two prosecution team members
prosecutors, there is no Sixth Amendment violation. Id. at
testified at the hearing that they lacked computer skills.
555, 97 S.Ct. at 843-44; see United States V. Kelly, 790
See Transcript at 77 (Vol. II-B); Transcript at 8 (Vol.
F.2d 130, 137 (D.C.Cir.1986). While there is a
II-A).
presumption that the information is conveyed to the
prosecution team, Briggs V. Goodwin, 698 F.2d 486, 495
(D.C.Cir.1983), vacated on other grounds, 712 F.2d 1444,
cert. denied, 464 U.S. 1040, 104 S.Ct. 704, 79 L.Ed.2d
169 (1984), the government may rebut that presumption
II. Conclusions of Law
by showing the existence of suitable safeguards, id. at 495
n. 29, or by demonstrating that "there will be no prejudice
[1] [2] A criminal defendant is guaranteed the right to the
to the defendants as a result of these communications."
effective assistance of counsel. McMann V. Richardson,
United States V. Mastroianni, 749 F.2d 900, 908 (1st
397 U.S. 759, 771, 90 S.Ct. 1441, 1449, 25 L.Ed.2d 763
Cir.1984). See generally Note, Government Intrusions
(1970); Coplon V. United States, 191 F.2d 749, 757
into the Defense Camp: Undermining the Right to
(D.C.Cir.1951), cert. denied, 342 U.S. 926, 72 S.Ct. 363,
Counsel, 97 Harv.L.Rev. 1143, 1150 (1984).
96 L.Ed. 690 (1952). The attorney-client privilege, while
it has not been elevated to the level of a constitutional
[6] Under Weatherford and Kelly, four factors are relevant
right, see, e.g., United States V. White, 970 F.2d 328, 336
as to whether an alleged intrusion into the attorney-client
(7th 1992), is key to the constitutional guarantees of
privilege offends the Constitution: (1) whether evidence
the right to effective assistance of counsel and a fair trial.
to be used at trial was obtained directly or indirectly by
Coplon, 191 F.2d at 757. To provide effective assistance,
the government intrusion; (2) whether the intrusion was
a lawyer must be able to communicate freely without fear
intentional; (3) whether the prosecution received
that his or her advice and legal strategy will be seized and
otherwise confidential information about trial preparation
used against the client in a criminal proceeding. See
or defense strategy as a result of the intrusion; and (4)
United States V. Levy, 577 F.2d 200, 209 (3rd Cir.1978);
whether the privileged information was used or will be
United States V. Rosner, 485 F.2d 1213, 1224 (2nd
used to the substantial detriment of the defendants.
Cir.1973), cert. denied, 417 U.S. 950, 94 S.Ct. 3080, 41
Weatherford, 429 U.S. at 558, 97 S.Ct. at 845; Kelly, 790
L.Ed.2d 672 (1974). One of the principal purposes of the
F.2d at 137. While neither the Supreme Court nor this
attorney-client privilege is to promote the free and open
Circuit have yet explained how these factors are to be
exchange between the attorney and client, see Fisher V.
weighed, and the other circuits remain split, see Kelly,
United States, 425 U.S. 391, 403, 96 S.Ct. 1569, 1577, 48
790 F.2d at 137 & n. 5, it is clear that there must a
L.Ed.2d 39 (1976), and substantial questions of
substantial demonstration of prejudice before an
fundamental fairness are raised where, in connection with
indictment can be dismissed. See United States V.
a criminal prosecution, the government invades that
Morrison, 449 U.S. 361, 365, 101 S.Ct. 665, 668, 66
privilege. It matters little whether the intrusion occurred
L.Ed.2d 564 (1981).
prior to the initiation of formal adversary proceedings, see
Kirby V. Illinois, 406 U.S. 682, 689, 92 S.Ct. 1877, 1882,
In this case, there can be no doubt that the government
32 L.Ed.2d 411 (1972), because the right to a fair trial
intentionally invaded the attorney-client privilege. The
could be crippled by government interference with the
government all but concedes that materials subject to the
attorney-client privilege long before the formal
privilege were reviewed during the execution of the
commencement of a criminal proceeding.
search warrant and more were seized and sealed.¹⁰
Stevens, an attorney assigned to the Department of
[3] [4] [5] "An independent judiciary and a sacrosanct
Justice's Fraud Section, testified that she read most (but
confidential relationship between lawyer and client are
not all) of the potentially privileged materials to
the bastions of an ordered liberty." Edna Selan Epstein,
determine whether the crime-fraud exception applied.
The Attorney-Client Privilege and the Work- *840
Moreover, at least one agent, PLA Rebecca Granger, read
Product Doctrine 2 (3rd ed. 1997). Nonetheless, not every
materials for which Defendant Denis Neill's counsel
intrusion on the attorney-client privilege constitutes a
asserted privilege during the search of Denis Neill's
constitutional violation. Under Weatherford V. Bursey,
home. These intrusions were not accidental; they were
429 U.S. 545, 554, 97 S.Ct. 837, 843, 51 L.Ed.2d 30
deliberate and intentional.
(1977), an intrusion may result in a constitutional
violation if privileged information is intentionally
[7] [8] While the parties dispute whether courts have
obtained and used to the defendant's detriment at trial.
sanctioned the Department of Justice's "taint team"
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U.S. V. Neill, 952 F.Supp. 834 (1997)
procedures,¹³ it is clear that the government's affirmative
ensure that the prosecution team did not have access to
decision to *841 invoke these procedures constitutes a per
the potentially privileged documents or become aware of
se intentional intrusion. See Weatherford, 429 U.S. at 558,
the content of those materials. When potentially
97 S.Ct. at 845; Kelly, 790 F.2d at 137.14 Where the
privileged materials were later inadvertently discovered
government chooses to take matters into its own hands
among the sixty boxes of seized items by Agent Fort, a
rather than using the more traditional alternatives of
prosecution team member, he acted responsibly by sealing
submitting disputed documents under seal for in camera
the materials without reading them. He then had them
review by a neutral and detached magistrate or by
delivered to the taint team for review.
court-appointed special masters, see, e.g., United States V.
Zolin, 491 U.S. 554, 570-71, 109 S.Ct. 2619, 2629-30,
The defendants contended at the evidentiary hearing
105 L.Ed.2d 469 (1989); In re Grand Jury Proceedings,
(generally through bench conferences the transcripts of
867 F.2d 539, 540 (9th Cir.1989); In re Impounded Case,
which have been sealed) that the government acquired
840 F.2d 196, 202 (3rd Cir.1988); In re Berkley and
information that will be used to their detriment. However,
Company, 629 F.2d 548, 550 (8th Cir.1980); United
based on the Court's independent review of the
States V. Osborn, 561 F.2d 1334, 1338-39 (9th Cir.1977);
defendants' sealed filing for in camera review (and
In re Subpoena Addressed to Murphy, 560 F.2d 326, 331
contrary to the defendants' assertion), there is no evidence
(8th Cir.1977); Hartford Assocs. V. United States, 792
that the government acquired the defendants' trial theories
F.Supp. 358, 367 (D.N.J.1992), it bears the burden to
or strategy. Compare Levy, 577 F.2d at 210 ("actual
rebut the presumption that tainted material was provided
disclosure of defense strategy").
to the prosecution team. Briggs, 698 F.2d at 495 n. 29
("The government is, of course, free to rebut this
[10] [II] At most, the potentially privileged materials
presumption, by showing, for example, procedures in
reviewed by the government contained facts identifying
place to prevent such intragovernmental
entities and persons. *842 Cf. Upjohn Co. V. United
communications.").
States, 449 U.S. 383, 395-96, 101 S.Ct. 677, 685-86, 66
L.Ed.2d 584 (1981) (distinguishing between protection
[9] However, an intrusion into the attorney-client privilege,
provided to attorney-client communications and facts
standing alone, does not per se violate the Constitution. If
underlying those communications). While factual
the government demonstrates that no harm, that is, no
disclosures enabling the government to better investigate
privileged information regarding trial strategy or
its case could rise to the level of a Sixth Amendment
otherwise has been communicated to the prosecutors and
violation if substantial, see United States V. Castor, 937
used to the defendants' detriment, there is no
F.2d 293, 297 (7th Cir.1991), the disclosure of facts is
constitutional violation. Weatherford, 429 U.S. at 558, 97
presumptively less harmful than the disclosure of trial
S.Ct. at 845; Kelly, 790 F.2d at 137. In this instance,
strategy. Here the government has demonstrated to the
based upon the evidence and testimony offered at the
Court's satisfaction that no privileged information, factual
evidentiary hearing, including the demeanor and
or otherwise, flowed from the taint team to the
credibility of the witnesses as well as the Court's review
prosecution team. Consequently, there is no evidence of a
of voluminous materials submitted under seal for in
harmful disclosure resulting from the taint team's review.
camera inspection and the entire record in this matter, the
The only information that the prosecution team may
Court is satisfied that the government has carried its
possibly have acquired arose from Agent Fort's
burden to rebut the presumption of harm.
inadvertent discovery of Earl Glock's identity. After the
defendants' counsel reviewed the materials, Fort
First, the government took precautions to shield the
discovered the notebook with a tab marked "Earl
prosecution team from viewing potentially privileged
Glock/Attorney-Client." The inadvertent disclosure of
materials during the execution of the search warrants.
this fact does not constitute constitutional harm.
Only Agent Fort was present during the searches and then
only for a short time. Fort testified persuasively that he
In sum, the Court has not seen any potentially privileged
did not read the content of any potentially privileged
materials that were seized and presumably reviewed by
materials, and his testimony was not undermined on
the government and which can reasonably be construed as
cross-examination or through other evidence. Second, the
trial strategy. While some factual information was
prosecution team witnesses testified that, to their
reviewed by the taint team, the record in this matter,
knowledge, they received no privileged information from
including the in camera submissions, indicates that none
the agents who may have been exposed to potentially
flowed to the prosecution team. Agent Fort's discovery of
privileged materials, such as Agent Granger, the PLA on
the tab identifying "Earl Glock/Attorney-Client" can only
site during the search of Defendant Denis Neill's home.
be characterized as inadvertent. The defendants' argument
Finally, the taint team took sufficient precautions to
that the government derived its factual knowledge from
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U.S. V. Neill, 952 F.Supp. 834 (1997)
material protected by the attorney-client privilege is based
would be helpful to resolving the Motion to Dismiss.
on bare speculation, and, for the reasons stated above, it is
rejected.
[14] The defendants support their motion by arguing
fairness and noting specifically that the Court granted the
[12] [13] As to the computer files, the defendants' charge
government's request to supplement the record with a
fails at the outset simply because they have not shown
memorandum from Michael Shaheen of the Department
that they asserted the attorney-client privilege with
of Justice's Office of Professional Responsibility. See
respect to those materials. The proponent of the privilege
Order of December 9, 1996. The Shaheen memorandum
bears the burden to establish its existence, United States V.
simply reflects his finding that the Fraud Section engaged
(Under Seal), 748 F.2d 871, 876 (4th Cir.1984); United
in no misconduct.19 While the defendants did not object to
States V. Covington & Burling, 430 F.Supp. 1117, 1122
the government's motion to file the Shaheen
(D.D.C.1977), and absent the timely assertion of
memorandum, the Court notes that this document was
attorney-client privilege for each specific communication
already available to her as part of Ms. Corprew's files,
or document, no privilege will be recognized. United
which were submitted for in camera review based upon
States V. White, 970 F.2d 328, 334 (7th 1992). Since
the defendants' request at the evidentiary hearing. By
there is no evidence of such an assertion by the
granting the government's unopposed motion, the Court
defendants, it is unsurprising that neither Stevens nor
merely ensured that the Shaheen memorandum was also
Corprew were asked to review computer files. Indeed,
available to the defendants. The Court's Order of
Stevens testified that she was unaware of the existence of
December 9th simply establishes no equitable ground
these files. Nonetheless, even though there was no claim
upon which to grant the Motion to Supplement the
of attorney-client privilege, the government did
Record.
implement a computer taint team to review files on
computer disks.¹⁷ Absent the timely assertion of privilege,
In sum, the parties were provided a sufficient opportunity
the defendants cannot now complain.
to develop the evidentiary record, and the defendants'
request for disclosure of additional materials will be
denied.
III. Defendant's Motion to Supplement the Record
Over a month after the conclusion of the evidentiary
IV. Conclusion
hearing, the defendants filed a motion to Compel
Production and to Supplement the Record of the
Accordingly, it is hereby
November 4-5, 1996 Evidentiary Hearing ("Motion to
Supplement the Record"). At the hearing, the Court
ORDERED that the defendants' Motion to Dismiss is
consistently denied the defendants' request *843 that the
denied; and it is
government be required to produce to the defendants
copies of the government's internal memoranda,
FURTHER ORDERED that the defendants' Motion to
electronic mail and other materials which would reveal
Supplement the Record is denied.
the government's deliberations. However, in response to
the defendants' repeated requests, the Court eventually
IT IS so ORDERED.
ordered the government to produce certain internal
documents for in camera review. The government did so,
to the tune of two very full boxes of materials which
document the taint team's actions and trace internal
All Citations
Department of Justice communications to and from
Stevens and Corprew.18 The Court is not persuaded that
952 F.Supp. 834
additional disclosures are justified or that supplementation
Footnotes
1
While the Court has considered the in camera submissions of the parties (filed under seal), the Court has taken care not to disclose
the specific contents of those submissions in this Memorandum Opinion.
2
The Fourth Amendment issues stemming from the search have been resolved and are not presently before the Court.
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=== Page 9 ===
U.S. V. Neill, 952 F.Supp. 834 (1997)
3
Two categories of potentially privileged documents have been discussed in the course of litigating this motion: (1) communications
between the defendants and their counsel, which in the context of this criminal proceeding have constitutional significance; and (2)
communications between Denis Neill, as a lawyer, and his clients (including Kamel Fattah), which while such communications
may be privileged, they have no constitutional significance here.
4
No litigation directly resulted from the taint team's review because the defendants never filed any motions for a protective order or
under Rule 41(e) and because the government never contested the applicability of the attorney-client privilege or raised the
crime-fraud exception.
5
IRS Special Agent Sherry Brown also attended the meeting. Her contemporaneous notes were introduced into evidence at the
evidentiary hearing. See Defendants' Exhibit # 7.
6
Poole further testified that he "told them that the prosecution team would not review any of the documents as to which claims of
privilege had been raised until those questions were resolved." Transcript at 75 (Vol. I-B). While it is possible, as the defendants
contend, that as of the November 1, 1993, meeting, the prosecutor intended to return the letterhead documents without review,
whether he did so intend but later changed his mind is not relevant to disposition of the instant motion.
7
This letter does not appear to be the "smoking gun" that the government contends. While it could be construed, as the government
argues, to reflect defense counsel's acknowledgment that all potentially privileged materials would be reviewed, it can also be
reasonably construed to reflect counsel's understanding that he was to designate someone to assist in the segregation of
"letterhead" documents from other materials so that the former could be returned without review by the government. Nevertheless,
it is unnecessary to resolve this dispute in order to resolve the instant motion.
8
The defendants also challenge Fort's presence during the search of the office of Neill and Company on October 27, 1993.
However, Fort denied reviewing any documents during the search or discussing the contents of any documents with the seizing
agents, see Transcript at 80-81 (Vol. I-B), and the defendants have offered no evidence to the contrary.
9
Agent Brown testified that Fort wanted her to witness that, upon finding the potentially privileged materials, he sealed them
immediately and did not read them. Transcript at 84 (Vol. II-B).
10
The government consistently contended at the hearing that the materials were only "potentially" privileged. However, the decisions
by the taint team to return to the defendants those documents for which the defendants asserted privilege, and to release to the
prosecution team only those for which the defendants did not claim privilege, does more than imply concession.
11
Neither side called Agent Granger to testify at the evidentiary hearing.
12
On the other hand, the discoveries by Agent Fort are most fairly characterized as inadvertent since he happened upon potentially
privileged materials after defense counsel had reviewed the boxes containing seized material. Fort testified that he was surprised to
find this material because, in fact, defense counsel and support staff had already inspected and inventoried the materials.
13
Although the more traditional approach is to submit contested materials for in camera review by a neutral and detached magistrate
(for obvious reasons), the case law regarding the government's "taint team" approach is equivocal. Compare In re Search Warrant
for Law Offices, 153 F.R.D. 55 (S.D.N.Y.1994) (criticizing "walling" in review of disputed attorney-client materials) with United
States V. Noriega, 764 F.Supp. 1480 (S.D.Fla.1991) (finding no Sixth Amendment violation where the government agent reviewing
monitored attorney-client conversations was "walled off" from prosecutors).
14
This decision is troubling indeed, and there is no doubt that, at the very least, the "taint team" procedures create an appearance of
unfairness. However unwise this policy decision may be, absent a showing of harm, it does not offend the Constitution. While this
Court is critical of the government's use of the "taint team" procedure, that criticism is not intended to carry over to the individual
attorneys who were assigned to perform as part of the taint team. The record reflects that these attorneys appreciated the sensitivity
of their assignments and took affirmative measures to ensure that no breach of the "walls" actually occurred.
15
In cross-examining the prosecution team members at the evidentiary hearing, the defendants contended that the government
acquired factual information identifying certain persons and business entities. However, with the exception of Earl Glock (who was
identified in a document discovered inadvertently), the government witnesses persuasively testified that those entities were known
to the investigators prior to the search. This testimony was not surprising. The investigation of the Neills and their business
activities dates to at least 1991, and the abundant record in this matter indicates that the scope of the investigation (even prior to the
searches of October 27, 1993) was wide ranging indeed.
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=== Page 10 ===
U.S. V. Neill, 952 F.Supp. 834 (1997)
16
As noted previously, Stevens returned certain documents without review based upon Roger's representations on or about
November 15, 1993.
17
The testimony at the hearing indicated that some of the files were printed and read by at least Agent Fort prior to the computer taint
team's review. Nevertheless, even though the defendants knew that the government had seized the electronic data and equipment,
they have not demonstrated that they asserted their attorney-client privilege with respect to any material stored electronically.
18
The communications were not limited to those between Stevens and Corprew.
19
While interesting, Mr. Shaheen's ethics determination for departmental employees bears little, if any, relevance to the
constitutional analysis under Weatherford and Kelly.
End of Document
© 2018 Thomson Reuters. No claim to original U.S. Government Works.
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c0:
=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com
To:
Subject: Ex-FDIC Staffer Found Guilty Of Stealing Banks' Living Wills
Date: Wed, 12 Dec 2018 08:22:13 +0000
Law360 White
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Wednesday, December 12, 2018
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to Azerbaijan has ended with a guilty plea in D.C. federal court that will result
Northern Trust Corporation
in six to 12 months in prison for the trip organizer, a former president of a
Penske Media Corp.
nonprofit formed to promote understanding between the U.S. and Turkish
Robert Half International Inc.
peoples. Read full article
Sanderson Farms, Inc.
SANCTIONS
The Bank of New York Mellon
Corp.
Huawei Exec Granted Bail By Canadian Judge
The New York City School
A Canadian judge granted bail on Tuesday to a top Huawei Technologies Co.
Construction Authority
executive facing extradition to the United States, the telecommunications
The State University of New York
giant announced. Read full article
Twitter Inc.
U.S. Legal Support Inc.
LEGAL ETHICS
Washington Post Co.
Cape-Wearing Chicago Atty Offers No Excuse For Client Theft
YouTube Inc.
A former Chicago personal injury lawyer known for dressing up in a cape and
ZTE Corp.
mask for a superhero persona known as "ExcuseMan" pled guilty Monday in
GOVERNMENT AGENCIES
a Chicago court to stealing his clients' settlements. Read full article
European Union
HEALTH
Federal Bureau of Investigation
Federal Deposit Insurance Corp.
Pa. Health Network To Pay $12.5M For Alleged Overbilling
Federal Reserve System
Federal prosecutors in Pennsylvania announced on Tuesday that they'd
Federal Trade Commission
inked a $12.5 million settlement with a Lehigh Valley health care network and
its CEO over alleged false Medicare and Medicaid claims for orthopedic
Financial Conduct Authority
surgeries. Read full article
Internal Revenue Service
New Jersey Attorney General's
IMMIGRATION
Office
New York State Police
NC Atty Charged With Aiding Client's Immigration Fraud
Office of Foreign Assets Control
A North Carolina immigration attorney has been accused of helping an
unauthorized immigrant use a U.S. citizen's identity to apply for Deferred
Securities and Exchange
Commission
Action for Childhood Arrivals status, the U.S. Department of Justice
announced Monday. Read full article
U.S. Attorney's Office
U.S. Department of Defense
Media Errors Hurt Political Chances, Ex-Sheriff Arpaio Says
U.S. Department of Justice
Former Arizona Sheriff Joe Arpaio hit CNN, HuffPost, Rolling Stone and
U.S. Department of the Treasury
several reporters with a $300.5 million defamation lawsuit in D.C. federal
court Monday, claiming that misreporting related to his since-pardoned
U.S. House of Representatives
misdemeanor conviction for criminal contempt has hurt his reputation and
U.S. Senate
political chances. Read full article
U.S. Supreme Court
United Nations
GOVERNMENT CONTRACTS
EFTA00032411

=== Page 3 ===
Contractor Admits Role In Sending Unqualified Guards To IRS
A manager for a company that provided armed guards to the IRS has pled
guilty to conspiracy to defraud the government in a scheme involving the
falsification of firearm shooting scores, prosecutors said Monday. Read full
article
TAX
Accountant Seeks No Prison Time For $18M Tax Return Fraud
An accountant found guilty of helping a venture capitalist siphon $18 million
from a fund through false tax returns has told a California federal court he
should serve no time behind bars despite prosecutors' request for a
"significant" prison sentence. Read full article
EXPERT ANALYSIS
A Review Of US Economic Sanctions In 2018
In 2018, the U.S. government strengthened sanctions targeting Iran, Russia
and Venezuela, sanctioned an agency of the Chinese government and
completed the second largest sanctions-related enforcement action on
record. And the evidence suggests 2019 will be equally tumultuous, say
attorneys with Ropes & Gray LLP. Read full article
Opening Comments: A Key Strategic Decision In Mediation
Opening comments by parties in mediation that are made with the proper
content and tone can diffuse pent-up emotion and pave the way for a
successful resolution. But an opening presentation can do more harm than
good if delivered the wrong way, say Jann Johnson and William Haddad of
ADR Systems LLC. Read full article
LEGAL INDUSTRY
US Legal Industry Saw Best Growth In Nearly 10 Years
This year has been the U.S. legal industry's best for growth in nearly 10
years, with firms at the large and small ends of the scale reaping the vast
share of the rewards, according to a report released Tuesday. Read full
article
Legal Hiring Poised For Boom In 2019
Nearly half of U.S. lawyers in charge of hiring say their law firm or corporate
legal department is poised to expand in the next six months, with the majority
predicting that litigation will be the biggest driver of that growth, according to
the results of a survey released Tuesday. Read full article
Microsoft Singles Out Davis Wright For Diversity Efforts
Microsoft Corp. on Tuesday recognized Davis Wright Tremaine LLP as the
top-performing law firm participating in its diversity program, as the
technology company celebrates the 10th anniversary of its effort to address
diversity issues in the legal industry. Read full article
Senate OKs Trump's 8th Circ. Pick Despite Flake Opposition
The U.S. Senate relied on Vice President Mike Pence for the first time to
confirm one of President Donald Trump's appeals court judges, as he cast
the tie-breaking vote for Eighth Circuit nominee Jonathan Kobes over the
objections of Sen. Jeff Flake, R-Ariz. Read full article
California's Harris To Keep Senate Judiciary Seat
California is set to have both of its senators on the Senate Judiciary
Committee next year, as a leadership deal allowed potential presidential
candidate Sen. Kamala Harris, D-Calif., to keep her spot on the panel. Read
full article
EFTA00032412

=== Page 4 ===
Court Reporting Co. Must Follow Calif. Regs
A California state appeals court refused Friday to revive a court reporter's
unfair competition suit against major court-reporting firm U.S. Legal Support
Inc., but held that a lower court incorrectly absolved the company of the
obligation to comply with California regulations for licensed professionals.
Read full article »
Stormy Daniels Owes Trump Attys $300K In Fees, Sanctions
Stormy Daniels must pay President Donald Trump's attorneys approximately
$300,000 in fees, costs and sanctions, which was less than half of what they
originally sought, a California federal judge ordered Tuesday following the
dismissal of the adult film star's defamation suit against the president. Read
full article »
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Boston, Massachusetts
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EFTA00032413


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=== Page 1 ===
thanks
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Office:
>>>
7/26/2019 10:10 AM >>>
I believe they gave it to him.
>>>
7/26/2019 9:22 AM >>>
did they bring it back
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Office:
>>>
7/26/2019 9:22 AM >>>
Chong said that they are giving him 15 days worth of his Colace and a half of bottle of milk of magnesia to self carry instead of 30
days worth of Colacea and a full bottle of milk of magniesia.
CONFIDENTIAL
SDNY_00009781
EFTA00033985


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=== Page 1 ===
From:
"
)"
To:
)"
:
(USANYS)"
Cc:
Subject: RE: Phone numbers
Date: Wed, 28 Jul 2021 23:06:32 +0000
Attachments: 2021.07.28_Court_Subpoena_-_AT&T.pdf,1 2021.07.28_Court_Subpoena_ - T-Mobile.pdf
Thanks! Subpoenas attached.
From:
Sent: Wednesday, July 28, 2021 5:25 PM
To:
is
)
is
(USANYS)
Cc:
Subject: Phone numbers
Hey
I apologize. I had this drafted and did not hit send. See below for the phone numbers we discussed.
T-Mobile
AT&T
Attn: Global Legal Demands Center
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
EFTA00031977


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=== Page 1 ===
From:
CRM)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Revised MLA request: Material Witness PA
Date: Mon, 30 Mar 2020 21:11:32 +0000
Attachments: Material_Witness_PA_330_DRAFT_UK_MLAT_request.docx
-
Here are some proposed revisions. Please take a look and let me know what you think. I think
we can get by without the complete set of direct exam questions for now.
Best,
U.S. Department of Justice Attaché
United States Embassy - London
(primary email address)
secondary)
EFTA00032129


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=== Page 1 ===
PRIVATE AND CONFIDENTIAL
Dear
It has been a long time since we were here in
together and that meeting is often in
my thoughts. I hope that you are all well. I am so grateful we managed to speak despite the
pandemic - thank you for travelling to see me. I hope that you received the additional
information sent to you a while ago
Please can someone let me know if it is possible to listen in on the trial or get daily
transcripts? No one has been in touch with me since we spoke. My understanding was that
victims would be kept informed of events? Please can you tell me who I contact?
I specifically wanted to let you know that
EFTA00032599

=== Page 2 ===
I feel that some people don't
see me as a real person with feelings. I feel completely exposed to a nightmare that I have
been so violently thrown into without my consent or voice this is one of the reasons why I
so appreciated being able to speak with you in
to set the record straight.
Something that struck a chord with me was written by the author Chimanda Ngozi Adichie:
'In this age of social media, where a story travels the world in minutes, silence sometimes
means that other people can hijack your story and soon, their false version becomes the
defining story about you. The assumption of good faith is dead. ,
Yours sincerely,
EFTA00032600


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=== Page 1 ===
To:
From:
Sent:
Tue 7/9/2019 7:08:17 PM
Subject:
Suicide Watch/Psych Observation Update
TEXT.htm
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
2. Gebremariam #79792-007 (Forensic)
Thank you,
CONFIDENTIAL
SDNY_00009862
EFTA00034014


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=== Page 1 ===
SYCH OBSERVATION LOG
NAME: EPstein
REGISTRATION#: 76318-054
OBSERVATION STARTED: 7-24-2019
OBSERVATION ENDED: 7/30/15
PLEASE RETURN LOG TO PSYCHOLOGY AFTER THE
OBSERVATION HAS ENDED.
THANK YOU.
ITEMS ALLOWED:
Regular Clothes
Safety Toothbrush
Newspaper/Magazine
Books (softcover only)
Safety Pen and Paper
Toilet Paper
Legal Mail
Other
SW Blanket & SW Mattress must be used even on Psych
Observations.
If nothing is checked with a silver marker, only a Suicide
Smock and Suicide Blanket are allowed.

=== Page 2 ===
Name of Inmate On Suicide Watch or Psych Observation: Epstein
Registration #: 76318-054
EATING/SHOWER CHART
DATE
BREAKFAST
LUNCH
DINNER
LIQUIDS
OFFERED
RECEIVED
SHOWER
SHOWER
7/23
Hg
/
2/24/19
1552
7/25/19
17/26/19
N
177
\
\
7/27/19
\
7/28/19
7/29/19
S
11VJS
\
\
7/30/19
Please check the appropriate box if the person on
Suicide Watch/Psych Observation actually eats his
meal. Do not check the box if he just received it,
but did not eat it.
Place a check in the "Liquids" box each time the
person drinks.
Thank you.
CONFIDENTIAL
SDNY_00009179
EFTA00033716

=== Page 3 ===
Epstein # 76318-054
7-24-2019
8:40 F/M Epstein is taking a Shower
845AM The L/T come a Fuck him up V
11:00AM Finish Shift Richard Martney 27758050
8:00pm IL English assumes Besponsably for Psych cell
7-24-2019 Observation for I/M Epstein 76318-054
8:15pm I/M Epstein is talking to Unit 2 officer.Co E
5:30pm I/M Epstein is talking to Unit2 officer €
E
8:45pm I/M Epstein is asking me about Jail life.
7,00pm
I/M Epstern and I are talking about Sail CE
CE
9:15pm
I/M Epstein ask me the time,
7:30PM I/M EDSTEIN ask me about lifein the House
CE
3:45pm I/M Epstein is laying awake on his bed
(E
10:00 pm
I/M EDSTEIN appears to be sleeping-
E
10:15pm
I/M Epstein appears to be Sleeping
of
10:30pm
I/M Epstein appears to be Sleeping
0:45pm I/M Epstein is quake and brushing his teeth
CE
11:00pm
I/M Epstein is laying on his bed
CE
11:00pm
End Sh.ft
1100m 1, Brendor DeCAPUA #16520 -055 sessumes
responsibilityfor the Psychopbservation watch ot inmate
Epstein # 76315-054 in cell=4 on 7/24/19 -
at 1100 PM Bhadlan
BD
1155PM Inmate EPSTE D is sleeping
BD
CONFIDENTIAL
SDNY_00009180
EFTA000337

=== Page 4 ===
1+5PM 30 PM Imate EPSTEIN is sleeping
BD
Imate EPATEINIS sleeping
80
1200 AM
125
lamate EPSTEIN is sleeping
BD
AM
inmate EPSTEIN is sleeping
BD
1216 AM
Staff Count
BD
1230 AM
1245
lamate EPSTEIN issleeping
BD
AM
100
lamate EPSTEIN is sleeping
BD
AM
mate EPSTEIN is sleeping
BD
113M
128
AM
Lt Rounds
hmate EPSTETN is sleeping
BD
BD
130m
145
limate EPSTEIN is sleeping
BL
AM
BD
209
AM
2'5 AM
Imate EPSTEIN is sleeping
Inmate EPSTEIN is sleeping
BL
imate EPSTEW is sleeping
R
X 930 AM
245 AM
Irmate EPSTEIN 15 sleeping
a
30AM
315 AM
Imate EPSTEIN is sleeping
Imate EPSTEIN is sleeping
BI
B
330 AM
Imate EPSTEIN is sleeping
8
Imate EPSTEIN is sleeping
B
345 AM
400AM
Imate EPSTEIN is awake drinking(water)- B
415 AM
Imate EPSTEIN is loying down
Inmate EPSTEIN is sitting on hisbedquiet- B B
430 AM
Inmate EPSTEIN is laying down
E
CONFIDENTIAL
SDNY_00009181
EFTA000337

=== Page 5 ===
EpstEIN # 76318-054
445 4 AM Inmate EPSTEIN is sleeping
BD
50AM Inmate EPSTEIN is sleeping
513 30 Immate EPSTEIN is sleeping
BD
5AM trmate EPSTEIN is sleeping
BD
100 545 Imate EPSTEIN is sheeping
BD
I AM Inmate EPSTEIN is sleeping
BD
6½m hmate EPSTEIN is awake sitting orbed BD
130, O 45 AM Imate EPSTEIN is awake sitting on on bed-BD
D
70Pm Imate EPSTEIN is awake sittingo on bed BD
AM Inmate EPSTE IN is awake sittingon bed BD
7 15 M limate ERSTEIN is awake siting on bed BD
730m Imate EPSTE IN is awake sitingonbed BD BD
731AM End of Shift Day
735A-LUIS Fernandez # 76268-054 assumes responsibility
for 1/m Epstein # 76318-054.
LF
750 J, E Chillen Psrd VISI by -) Larev
745 AM. 1/m Epstein appears to sleeping - LF
of Sty had
Em
830 11m Epstern when to Legat
900 - End of shift-
1:40 I/C MERSE +89673-053 assumes
UCH
responsibility for I'm Epstem # 76318-054
99 Item Epsters just returned bronalegal visit
udal
CONFIDENTIAL
SDNY_00009
EFTA0003

=== Page 6 ===
Eastern ts 76318-054
8:00 I/m Fsstrue and I are discussing
was
investment strategies
8:55
I/m discussion Epstein and Tarp continuing the
was
8:70
I'am Epstem and Iare nowdiscecting
we
invete sofely his inviote safety
8:45 I/m E stem isasking more questions like
aboutprison adjustment
9:00
Ilan Esters box paused to waste
was
his for
7:15
Item Epstern is lying down for arest
WID
9:38
make CO HE
a30
I'm Ersteni is asleept
were
7:45
Ilen sitein continues at rest
wos
0:00
There Efiter lying on unbis back asleep
visa
0.15
I/W Essten motionaless and opparently
460
asley ou his bunk
0:30
Ifen Esstem is asleep and smoring
was
10:45
up for Q second and
now lyingdown again
0.55
END SHIFT
wesa
10.55pml, Brandon DeCapue #16520-055 (conte)
CONFIDENTIAL
SDNY_00009183
EFTA00033720

=== Page 7 ===
EBSTEIN # 76318-054
(cont'd) assumes responsibility for the
psych observation of invote EPSTEIN
# 7631 8-054 in cell=4 on 7/25/19 at
1055pm, BKDG
BD
1100 PM Inmate EPSTEIN is laying down quiet
BD
11'PM Imate EPSTEIN is sleeping
BD
1/30 PM Imate EPSTEI IN is sleeping
BD
1145m ImateEPSTEIN is sleeping
BD
1209 AM Staff rounds
1200m Inmate EPSTEIN is leeping
BD
1215 AM 1/nmate EPSTEIN is sleeping
Page
1230m Imate EPSTE 150 is sleeping
BI
1245m Imate EPSTEI Wis sleeping
8
1°Am Immate EPSTEIN is sleeping
K
115 AM Inmate EPSTETNIS J skeping
BD
127 AM LT Rounds
BD
130 AM Imarke EPSTEIN is sleeping
BD
2000 Imate EPSTEIN is sleep ng
145m / imate EPSTEIN is sleeping
25 AM Inmate EPSTEIN is seeping
B
230 AM Immate EPSTEIN is sleeping
BD
256 AM End of Shift
245 AM Innate EPSTEIN is sleeping
BD
CONFIDENTIAL
SDNY_0000918
EFTA00033

=== Page 8 ===
EPSTEIN # 76318-054
3:cm F/C (kima Pineda assumes Responsability
3.00 85918-0054
for psych cell#4 I/m Epstein 27758-050
JFG
2:00 S'am inmate Epstein is sleeping
JF6
2005
Socim
inmate Epstein is awake using the bath
JFG
30am 2015 inmate Epstein D awake steo sleeping
JFG
3:30m inmate Epstein is sleeping
SFG
3:am 2.45 Inmate Epstein Is sleeping
JF6
4:am inmate Epstein 1) sleeping
JFG
4.am inmate Epstein is sleeping
JFG
11.30 1:am inmate Epstein 13 sleeping
JFG
4.45 immate Epstein b sleeping
JFG
S:am inmate@pstan wake up to use bath and back to sleep- 56
5:15 inmate Epstein IS steeping
5FG
5:30am (.45 inmate Epstein is sleeping
JFG
Sam
inmate Epstein 13 sleeping
JFG
6:00
inmate Epstein is sleeping
JFG
6:15
am
Inmote Epstein 1) sleeping
JFG
6:30
am
us
inmate Epstein IS sleeping
JF6
6.am
inmate Epstein 1) sleeping
JFG
7:am
inmate Epstein IS sleeping
JFG
7.am
Inmate Epstein 1) sleeping
Jf6
7:3am
inmate Epstein IS sleeping
7:37
r.am
Staff rounds
5f6
CONF IDENTIAL
SDNY_000091
EETA0003

=== Page 9 ===
EPSTEIN # 76318-054
7.39 am inmate Epstein Recived breakfast
JFG
Oth LL Did 7-26-19
7.41 tiam inmate went to medical (dentist)
JF6
7:43 am inmate still in dentist
JFG
- End of shift
5f6
X7:53M I/M Epstein IS IN THE SHOWER
(y
7.54
AM I/M/C DUNCAN 86764054 ASSUMES
Responsibility FOR Epstein 76318-054 IN
CELL#4 ON PSYCH OBSERVATIONS ON 7-25-19 KD
8:00AM I/M EPSTEIN IS Still [URRENTLY In the
SHOWER
KD
8:15AM
I/M Epstein IS Daying OFF From His SHOWER
IN Hrs EELA
KD
SISA
RE Ruller, Pard visit t review
of by boah
Eng
9:00AM I/M EPSTEIN'S Sitting ON BED waiting
ON A LEGAL Visit
KD
9:15AM I/M Epstion IS BrusHing H.S Telth
KD
9:30 AM 2/m EPSTEIN IS Sitting ON BED
KD
9:45 AM I/M EPSTEIN IS LIAVING Fore Legal visit - KD
END OF SHIPY
BEGIN SUIFT I/C TISDACE 78359053 ASSUMES RESPENSIBILITY
For PSYCH OBS OF I'M EPSTEN # 76318-054
ON 7/26/19 IN 611 Hy, mo
CONFIDENTIAL
SDNY_0000

=== Page 10 ===
CONTINUED ON net page (no)
Reg
DATE
CONFIDENTIAL
SDNY_00009187
FFTA00033724

=== Page 11 ===
Continued ON Next page (No)
CONFIDENTIAL
SDNY_00009188
FFTA00033721

=== Page 12 ===
PSTE.N # 76318-054
19.0 I/M EPSTEN AFTIVES From LEGAL visit - nt
Taxis Dim EPSTEIN RECEIVES Four from c/o
19:30 I'm EPSTEN INQUINES ABOUT B.U & Pulicy
INCI PHINE USAGE AND VISITS
am
2:00 Dim EPSUIN is GAT.M
20:15
Rown made
1-1 E.
2030 I'm EPSTEN is Tallcino ABOUT Business
20:45 I'm EPSTEIN is LYNU DOWN
no
20:00 I'm EPSTEN CS TALKING ABOUT BUSINESS + INVESTING
21:15 I'm EPSTEIN is Discussing BUSINESS + Life Lessons
21:30 I im GBSTEIN APREADS TO BE LYING Dan
21:45 I'm CPSTEN Appears TO BE Sceeping
*21:50
C/O ROUNDS
M
: 22:00 I'm EPSICIN APPEARS to BE SLeeping
22:15 I/M CPSTEIN NBE swer
22.30 I'm EPSIEN ASKS Ate TIME uses DE Tabt +
-
Brushes his Teeth
22:45
Fim EPSTEIN Returns to LYING Down
23.00
cim Gestern AOPEANS N BE sleepids
23:15 Dim & Pisle.n APPEALS nose SLEPING
23.30 I'm Ens6in APPROMS N BE SCOP,D
of
23:45 I'm EPGLE To Be seep.
0:00 I'm EOSTEIN APPGANS n BE SleeDing
CONFIDENTIAL
SDNY_00009189

=== Page 13 ===
EPSTEIN# 76318 - 054
O:15 I'm EPSTEIN APPEARS to BE SCOOPING
M
O30 C/O ROYNDS
As
0.45 I/m EPSTEIN APPEARS to BE sleeping
a
01:00 I'm EPSYEN APPCIAS to BE sceeping
a
exits I/m Epstern APPEARS PU BE SHOPPING
1:30 I'm EPSTEIN APPEARS a BE SCOOPING
its
urius I/m EPSTEIN APPEARS n BE SLEEPING
NT
02:00
I/m EPSTEIN APPEARS to BE SLeePING
That
02:15
I'm EPSTEIN GETS up TU CUASH FACE (FE
I
TACKS ABOUT NOT WANTING to Go TO SHU in
-
Lieu D.F COING in A UNIT. IN QUINES ABOUT THE
)
-
CONDITIONS JF VAAVOUS UNITS
02:30 I I/m EPSTEIN INQUIRES ABOUT THE ATMOSPITERE
/
OF VArious Pre-Triac UNITS in MCC
I
02:45 I'M I'm EPS-K.N APPEADS to BE SLEEPING
(ND SUIFT I/C TISDAG # 78354-0503
mn
3:00AM I'C Armando Davila asuming responsability of epstein # 76318-054
Besin shift
3:00 aM '/M epstein is sleeping
ADAC
3:15am. '/M epstein is sleeping
ADAC
3:30 am IM epstein is sleeping
ANAC
CONFIDENTIAL
SDNY_00009190
EFTA0003372

=== Page 14 ===
Epstein # 76318-054
7/27/19
3:45 am '/M epstein is deeping
ADR
4:00 am '/M epstein is sleeping
ADAC
4:15am 'IM epstein is sleeping
ADAE
4:30 am 1/M cpstein is sleeping
AAAC
4:45am '/M eprtein is sleeping
ADAC
0:00 am I/M epstein is sleeping
ADAC
S.15am I/M epstein is sleeping
ANAC
5:30am 1/m epstein is sleeping
ANAC
5.45am 'IM epstein is sleeping
ANAC
6:00 am '/h epstein is sleeping
AnAC
6:15am I/M epstein is sleeping
ADDC
6.30 am '/M epstein is sleeping
ADAC
6:45am '/M epstein is sleeping
ADAC
6:50AM Dr I men to can life to intender
Mr Epiter
7:00
AM
I/M/C DUNCAN 86764654 ASSUMES Responsibility
OF Epstein # 76B18-054 IN CELL#4 ON psych
WATCH ON 7-27-19
KD
7:15AM 7: 3/M EPSTEIN ASKS FOR Toilet Tessue and TOOTH
PASTE which WAS FOUND IN the Supply Closet - KD
7:30 AM 2/M EPSTEIN S.T'S ON BED WAIting
on BECAKFAST
50
7:45 I/M Eps tein Sits ON 320
KD
CONFIDENTIAL
SDNY_00009191

=== Page 15 ===
Epstein # 763
7-27-2019
8.00 AM 2/M COSTEIN Sits ON BED
KD
8:55AM V/M EPSTEIN S.TS ON BED
Kg
8.30 AM 2/m EPSTEIN SUTS on BCD
KD
8:40AM I/M EPSTEIN WAS Just SERVED BREAKFAST KD
END OF SHIFT
8:00PM Star New Shift Richard A Martinez 27758050
The I/W Epstein Ju St got back from Regal RM
8:15 PM F/M Epstein 18 Using the toilet
RM
8:20 PM we call controll the toeles is not stoping
8:30PM I/M Epstein is Just Talking
RM
8:45 PM F/M Epstein is talking
RM
9200 PM F/M Epstem is Talking about the life-Rr
in the general population
RM
9:15Pm F/m Epstein is just Talking
RM
1:30PM I/m IS Just talking
RM
3:45PM 0:00Pm I/M E Pstein went to Sleep
RM
1/M EPstein appears to be sleeping
R
0:15 PM I/M Epstern appears to be sluping
RM
2:30 PM F/M Epstein appear to be sleeping
RM
0:45PM PM I/M Epstein appears to be sleeping - RM
1:00
/m IN Epoten appears to be Sleeping Rd
Finish the shot Richard Mortry 27758050
140
CONFIDENTIAL
SDNY_00009192
EFTA00033729

=== Page 16 ===
(Cont'd) responsibility for the psych observation
for inmate EPSTEIN #76318-058 in cell#4 on
7/27/19 at 1040PM, Box DC,
B
11°PM Inmate EPSTEIN is sleeping
BD
11'AM limate EPSTEIN is sleeping
BO
1145 PM Inmate EPSTEINIS sleeping
1130 RM imate EPSTEIN is sleeping
BD
BE
1200 Imate EPSTEIN is sleeping
B
1204 AM StaffRounds
BD
1215AM Imate EPSTEIN is sleeping
B
1230m Imate EPSTEIN is sleeping
B
1245 AM hmate EPSTEIN is sleeping
d
10PM Imate EPSTEIN is sleeping
BD
195 AM Imate EPSTEIN is sleeping
BC
130AM Imate EPSTEIN is sleeping
BE
145 AM Inmate EPSTEIN is sleeping
B
200 AM Imate EPSTEIN is sleeping
2'5 AM Inmate EPSTEIN is sleeping
230m Imate EPSTEIN is sleeping
245 AM hmate ERSTEIN is sleeping
300 AM Imate EPSTEIN is sleeping
315 AM Inmate EPSTEIN is sleeping
3 End of shift Bil DC,
CONFIDENTIAL
SDNY_0000

=== Page 17 ===
Epstein # 76318-059
7/28/19
3.15Am 1/c Armando Davila asuring responsability for Epstein
# 76318-054 Besin shift
MAC
3:30 Am 'IM Epstein is sleeping
ADAE
3:45AM '/M Epstein is sleeping
ANAC
4:00 AM '/M Epstein is sleeping
ADAC
1.15AM 1/M Epstein is leeping
ANAC
4:30PM '/M Epsteins is sleeping
Ante
445AN 4M Epsteins is sleeping
ADK
3.00.Am '/M epstein is sleeping
ADAC
S:15 AM '/M Epstein is sleeping
ADAC
5:30 AM I/M Epstein is sleeping
ADAC
S:45AM 'M Epstein is sleeping
ADAC
6:00 AM '/M Epstein is sleeping
MAC
GISAM '/m Epsten is Awake and Say call doctor
ADAR
6:30 Am 'M Epstein is sitting or the bed - Anac
6:45 AM 1/M Epstein is sittim on the bed - ADAC
7.60AM TO Arnad Davila end shift
ANAC
65½/Am Dr Imon to review les + to interier
Spetein
715ar '/M Epstein is sittins an the bed - ADRE
7:30 am '/M Epstein is sitting on the bad - ADAC
7:45am 'In Epstrin is taken breakfort
ANAE
8:00 am I/M Epstein is stand and walk
ANDC
CONFIDENTIAL
SDNY_00009194
EFTA00033731

=== Page 18 ===
*g.00 FIM I/M/C DONCAN 86764054 ASSUMEING RESponsibility
FOR EPSTEIN 76318-054 ON PSYCH WATCH
IN CELL # 4
KD
8:15AM I/M EPSTEIN COMPLAINS ABout To.le+
NON-Stop FLUSHING FOR ABOUT 45mins
KD
8:30AM F/M EPSTEIN Sits ON BED AND WAIT'S
FOR LT TO COME get Hirs FOR A LEGAL
Visit
3
8:45AM Flor EPSTEIN LAY'S ON BED AWAKE
PATIENCELY writing-
KD
9.00m 3/m EPSTEIN IS FAST Asleep
KD
9:15AM I/M EPSTEIN IS Still slipping
ND
K9.28M F/M EPSTEIN WAS TAKEN By LT to
MEET with HIS LEgAL visit
KD
9:38M
/M EPSTEIN Isnt IN CILL AT this
TIME
KD
9.45AM
F/M EPSTEIN Still out on Light
KD
10:00AM F/M EPSTEIN Stin out ON Ligar
250
10:17am Duty officer rounds
Cn
10:30 AM 3/M EPSTCIN Still out ON LEGAL
KD
10:45 I/M EpsteIN Still out ON Legal
KD
11:00AM Flu EPSTOIN Still out ON LEgAL
S
END OF SHIFT

=== Page 19 ===
11:00am Immate Companion Oman Esteban
assumes responsibility for
immate Epstein on all # 4
111/5am Immate Epstein is out on
legal visit
ot
Dlw W RDS carlab
1.300m visit Immate Epstein is outona legal
of
11:45am Immate Epstein is out on a
legal Visit
at
12-00pm Immate Expsteen is out on
a legal visit
ot
12:15pm Immate Epstein is still out
230pm Immat Epstein is stillout
on legal (risit
or
1245pm Immate Expitein is still
on legal visit
ot
out on legal -Visit
3
1.00pm Immate Opstein is still
115pm Inmate Epstem is out on
out on legal nisit
legal visit
CE
130pm lmmate Epstein is still on'
CONFIDENTIAL
SDNY_0000

=== Page 20 ===
Epstein # 76318-054
on legal visit
OE
1:45pm Immate Epstem is on legal visit C
7.apm Immat Expsteen you legal of
15pm Ment Ammat Eqostern voul on
legal meit
ex
230pm
Immate Epstemisous on legal
Visit
ot
ERROR
E
END OF SHIFT
90370
2:45PM INMATE COMPANION CHAN ASSUMES RESPONSIBILITY FOR INMATE EPSTEIN
703 76318-054 ON PSYCH WATCH IN CELL#4 07/28/19
M
2:45 PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
M
3:00 PM
INMATE EPSTEIN IS OUT on LEGAL VISIT
3:15 PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
( 3:30PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
3:45PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
4:00PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
I
4:15PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
4: 34PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
4:45PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
5: 00 PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
M
5:15 PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
CONFIDENTIAL
SDNY_0000919
5FTA:

=== Page 21 ===
EPSTEIN 76318-054
07/28/19
5: 30PM INMATE EPSTEIN IS OUT ON LEGAL VISIT
Me
540
Lt RDS
N
5:45PM
INMATE EPSTEIN IS OUT ON LEGAL VISIT
MC
6:00PM
INMATE EPSTEIN IS OUT ON LEGAL VISIT
MC
6:15PM
INMATE EPSTEIN IS OUT ON LEGAL VISIT
MC
6:30PM
INMATE EPSTEIN IS OUT ON LEGAL VISIT
MC
6:45PM
INMATE EPSTEIN IS OUT ON LEGAL VISIT
MC
7:00PM
INMATE EPSTEIN IS OUT ON LEGAL VISIT
MC
END OF SHIFT as a
MC
7:00
I/C Mersey H 89673 053 assumes re-
404
sponsibility for Lopey #76318-054
7:00
I/W Lysey and Lardescussing Epsteins
460
situation WRON G BOOK
T.OO
I'c MERSEF II 89673-053 assumes
from
8:00
responsibility for I/m Epstein 76318-054
I/m Epstein is back from his legal visit way
8.15
Flan Epstein wonts to know whos the way
lest cook on 11 North
8:30
I/m Epsten is talking about investments EDUI
8:45
Ileu Epsteni and Farl talking about
you
driving a taxa in NY. We both
drove
9:00
down
with

=== Page 22 ===
Essten # 776318-054
7/28/19
9:15 Item Epstern asley
like
9:30
Ileu Epsten asleep
uva
9:45 Item Epatein lying still apparrilly
WIDELY
out for the night
10:00 I/m Epstem lying sidently on his bed
was
10:15
The Epatem mationiless and asleys
wore
10.30 I/m Esiteen stays asleys
was
10.44 T/w Ejasteen still silent
used
11:00 END SHIFT
upo
1100PM 1, Brandon DeCAPHA #16520-055-
assumes responsibility for the psych
observation of inmate EPSTEIN 76318-054
1100m
in cell#4 on 7/28/1924 DenBD BD
Inmate EPSTEIN is sleeping
11'5m
Innate EPSTEIN is sleeping
BD
1130m
30
Imatel EPSTEINIS sleeping
BV
1145m Inmate EPSTEIN is sleeping
BL
1200AM Impte EPSTEIN 's sleeping
BI
12 15 M Inmate EPSTEN is sleeping
BE
1230m Immate EPSTEIN is sleeping
BC
1253AM Staff rounds
1245m Imate EPSTEIN is sleeping
B
B
100 AM limite EPSTEI IN is sleeping
B
CONFIDENTIAL
SDNY_00009199
EETA000337

=== Page 23 ===
EPSteiN#76318-054 76318-054
7-29-2019
15Am Imate EPSTEIN is sleeping
BD
145 AM 130Am Imate EPSTEIN issueping
BD
Imate EPSTEIN is sleeping
BD
200
AM InmoteEpSTEIN is sleeping
BD
215 AM
Imate EPSTEIN is sleeping
BD
230
AM
Innate EPSTEIN is sleeping
BD
2th5m
252AM 2
Endo of shift Pt DJ
limate EPSTEIN isskeping
BD
ERROR
BD
252Am
Count
BD
258AM
End of ShiftBy DCp
BD
3:00 AM
start of Shift Richard MartiNez 27758050
I/M Epstein appears to be Sleeping
RM
3:15AM
IMEpstein appears tobe Sleeping
RM
3:25 AM
F/M Epstein went to the bathroom and ask about
time
RM
3:50 AM
I/M Epstein went back to sleep
RM
3:45 AM
I/M Epatein appears tobe Sleeping
RM
4:00AM
F/M pstein appears to be Sleeping
RM
4:15AM
I/M Epstein appears to be Sleeping
RM
4:30AM
F/m Epsteir appears to be Sleeping
RM
4:45AM
I/M Epstein appears to be Sleeping
RM
5:00 AM
I/M Epsten appears to be Sleeping
RM
5:15AM
I/M Epstein appears to be Sleping
RM
CONFIDENTIAL
SDNY_00009200
EFTA00033737

=== Page 24 ===
Epstein# 76318-058
7-29-19
5:30 AM I/M Epste in appears to be Sleeping RM
5:45 AM F/MEpsterm Just got Up be is Using
The bothworn
RM
6:00AM F/M Epstein appears to went back to Sleys
6:15AM I/M Epstern appears to be Sleeping
R
6:30AM I/M Epstein appears to be Bleeping - R
6:35AM the F come with the breakpost
Act UT c/y Row Fe
6.40AM The L/T offered the Shower the For Say yes and
ask for razor for Shazin
RM
the I/m is houng breakpost selting RM dow
air the floor
6:45AM F, tike For is taking a Show er
RM
7:00AM
got out of show
Famish Shift Richard Marting 277580
( 7:00AM
s/m/c DUNCAN 86764054 ASSUMES RESponibility FOR
EPSTEIN 76318-054 ON psych WATCH INCELL
#4 ON 7-29-19
KD
7.15
AM
I/M Epstein Drys OFF From SHOWER HE
Just took
KD
7:30
AM
3/m EPSTEIN Sits ON BED writing In
NOTE PAD
V
7:45
AM
1/M EPSTEIN IS Still writing
CONFIDENTIAL
SDNY 00009201

=== Page 25 ===
Epsten (I 76318-054 7/29/19
8.00AM F/M EPSTEIN IS Still writing
KD
9:5 I/M EPSTEIN IS St.11 writing
KD
8/30 AM I/M EPSTEIN IS using Betthoom
KD
8:45pm F/M lay's ON BED
KD
9:00 AM F/M Epstein Is Speaking with psygh - KD
915A In EMills Psych Visit and review
of log book
EM
1:30 P: AM 3/m Epstein LAY'S ON BED with Eye's
Closed Resting
KD
9:45 AM I/M EPSTEIN IPPEARS to BE SLEEP -
KD
10:00AM I/M EPSTEIN IS Still ASIEEP
KD
10:15AM 7/M EPSTEIN IS Laying ON BED RESTING KD
10:30AM I/M EpstEIN IS Still Resting
KD
10:45 AM I/M EpsteIN IS Fast ASIEQ
KD
1:00 T/M EPSTEIN IS Drinking WATER AT SINK KD
1:15AM J/M EPSTEIN IS Sitting ON the EDgE OF the
BED with His HEAD IN the PAIM OF H.S HANDS KD
11:20am 4M Epstein, IS ON His way to A LEGAL visit KD
11:40
END OF SHIft
8-70 I/m Epstern has returned from his legal visit wome
and is eating
3:45 I/m Fasteric and are talking about his
uns
internment options
CONFIDENTIAL
SDNY_0000920
EFTA00033

=== Page 26 ===
Epstemint 76318-054
7/29/19
9:00 Eleven Epatein istalling about hisbail we
offeal
919 they Epsteni and Faretalling investerents a
9:30 I/w Epsten is lying down now
6ca
9.45 I/m Epsten is sleeping
&D
10:00 Item Epsteric is askeys
easa
10:01 Rund mader
He
112
10:15 I/m Epstein is asleys
was
10:30 remains atrest
we
10:45 Item opstem continuing in slumber
used
10.45 END SHIFT
4ps
1045 pm limate Brandon DeCA944#14520-055-
assumesrespoisibility for the phych
observation.of inmate EPSTEIN # 76318-054
incell #4 or 7/29/19 of PMBLDG
11:5AM limate EPSTEIN is sleaping
1100m Imate EPSTEIN is sleeping
1130 PM lamate EPSTEIN is sleeping
1145 PM limate EPSTEIN is sleepings
1205M Staff rounds
1200AM Imate EPSTEIN is sleeping
1230 ImmateERSTEN is sleeping
12's AM Imate EPSTEIN is sleeping

=== Page 27 ===
1245 ImeteEPSTEIN issleeping
BD
100 AM Immate EPSTRIN is sleeping
BD
115 15 AM limate EPSTE iN's sleeping
BD
128AM trounds
BD
130 30 AM Imate EPSTEIN is sleeping
BD
45 45AM AM Imate EPSTEIN is sleeping
BD
200 AM hmate EPSTEINIS sleeping
Be
2.5AM ImateEPSTEW is sleeping
BD
239M i incte EPSTEIN is sleeping
245AM IMMOTEEASTEIN is sleeping
BD
300AM nmate EPPTEIN issleeping
BD
2020 AN End Shift
BI
3: 3:am 2.00 b/c Cama Pineda 85918-054 assumes
responsability for phuch tn 76318-054 in cell#4-JFG
J.am inmate Epstein 15 sleeping
2.15
JFG
3:20m innate Eptein 13 wake drinking water and
back to sleep after that
JF6
2.30 I.am inmate ts Epstein IS sleeping
JFG
Jam 2.45 inmate Epstein is sleeping
Jff
1:00 inmate Epstein 13 sleeping
Jf6
1.15 I'am inmate Epstein is sleeping
JFG
4:30 am inmate Epstein 10 sleeping
JFG
4:45 am inmate Epstein IS sleeping
JFG
CONFIDENTIAL
SDNY_0000920
EETA00033

=== Page 28 ===
Epstein 76318-054
7-30-19
5.00 am inmate Epstein IS sleeping
JF6
5:06 am inmate Epstein 15 awake sitting on bed
JFE
S.am inmate Epstein is skeping
Jfb
5:30 Inmate Epstein 13 sleeping
Jfb
5:45 am inmate Cpstein 15 sleeping
3f
61 am am inmate Epstein IS sleeping
JFG
6:15 am inmate Epstein IS sleeping
Jf6
6:30m inmate Epstein D awake
JE6
6.45 am inmete Cystein is talking to me about
jail life
JFG
7.00 f.am inmate Epstein its cating breakfast
JF6
7:00m am
And of shift
56
7100
AM Start of mew Shift Richard Martinez 27758050
5/m Epstein is having breakfast Cereal and Hdk Rr
7:15AM For Epstein is Steel exting
7/30/19 % M.J new
7:30 AM The 4T give the I/M breakfast the brown beg R
7:45AM I/m Epstern is setting dow n on his bed-RM
7 52AM Dr. Imen t avior left X intersion
Spetion
8 Am Dr Imei 5t,h interialing
8 15 Am Psy.h claimstion " being discutant
CONFIDENTIAL
SDNY 00009205


c1: EFTA00032155
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032155.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Special
Housing
Unit Management
Suicide Prevention
EFTA00032155

=== Page 2 ===
Single Cells
It is recommended that all SHU inmates be
double-celled unless there is a compelling
reason not to do SO.
- Reduces isolation
- Reduces privacy
- Provides distraction
- Provides rescue opportunity
EFTA00032156


c1: EFTA00032293
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032293.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: Epstein (FinCEN records)
Date: Tue, 13 Aug 2019 18:56:29 +0000
Did we ever get these?
Original Message
From:
Sent: Wednesday, August 7, 2019 3:00 PM
To:
Cc:
Subject: RE: Epstein (FinCEN records)
,
Will do.
Thanks
Original Message
From:
)
[mailto:
Sent: Tuesday, August 06, 2019 5:43 PM
To:
Cc:
i
i
)
i
Subject: FW: Epstein (FinCEN records)
,
Could you please pull the FinCEN records listed below and circulate to the team? It sounds like they're
potentially useful so we'd like to review. Thank you!
Original Message
From:
Sent: Tuesday, August 06, 2019 11:53
To:
Cc:
)
Subject: RE: Epstein
,
We wanted to make sure you all were aware of several records. See below - a list of relevant document IDs that
EFTA00032293

=== Page 2 ===
will allow you to pull the records up in FinCEN Query or cross-reference with your files. Please let me know if
you have any issues.
BSA IDs:
Thanks,
Original Message
From:
Sent: Monday, August 5, 2019 9:45 AM
To:
)'
Cc:
)
Subject: RE: Epstein
Sorry I was inartful. Yes, my understanding is that we have information to send your way.
can confirm that.
Assistant Chief Counsel
Financial Crimes Enforcement Network
This e-mail message and any attachments from the United States Department of the Treasury/Financial Crimes
Enforcement Network is for the exclusive use of the intended recipient and may contain privileged information,
including information protected by the attorney-client and attorney work product privileges. If you are not an
intended recipient, please do not read, distribute, or take action in reliance on this message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly delete this message
and its attachments from your computer system. Be advised that no privilege is waived by the transmission of
this message.
Original Message
From:
)
Sent: Monday, August 5, 2019 9:43 AM
To:
Cc:
Subject: [EXTERNAL] RE: Epstein
EFTA00032294

=== Page 3 ===
Hi
,
I had the impression from
email that you had particular documents or reports you were looking to
send our way ("so you can coordinate with them to make sure they have already seen any SAR information you
guys are looking at") -- if so, we would be grateful for you to send whatever it is you think would be useful. Or
please let us know if that's not correct (when
says "the relevant SAR information" I'm not sure what
that's referring to), and if so what it was you were envisioning.
thanks,
Original Message
From:
Sent: Monday, August 05, 2019 09:18
To:
Cc:
)
Subject: RE: Epstein
We just want to ensure you have the relevant SAR information you need. To that end, I'm copying
of
our Intelligence Division, with whom you can liaise directly if necessary.
Best,
Assistant Chief Counsel
Financial Crimes Enforcement Network
This e-mail message and any attachments from the United States Department of the Treasury/Financial Crimes
Enforcement Network is for the exclusive use of the intended recipient and may contain privileged information,
including information protected by the attorney-client and attorney work product privileges. If you are not an
intended recipient, please do not read, distribute, or take action in reliance on this message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly delete this message
and its attachments from your computer system. Be advised that no privilege is waived by the transmission of
this message.
Original Message
From:
)
Sent: Sunday, August 4, 2019 7:44 PM
To:
Cc:
Subject: [EXTERNAL] RE: Epstein
,
EFTA00032295

=== Page 4 ===
Thanks for reaching out, and let us know how we can best proceed.
thanks again,
Original Message
From:
Sent: Friday, August 02, 2019 20:17
To:
)
3
Cc:
)
;
)
Subject: Re: Epstein
Thanks so much for the introduction,
I'll have the folks on my end reach out to confirm the status of this.
Thanks again and nice weekend to all.
From:
)
3"
<mailto:
Date: Friday, August 2, 2019 at 7:00:36 PM
To:
<mailto:
Cc:
)"
<mailto:
)"
<mailto:
Subject: [EXTERNAL] Epstein
,
As discussed, I'm cc'ing a couple of the AUSAs on the Epstein team so you can coordinate with them to make
sure they have already seen any SAR information you guys are looking at, or pass it over if they haven't.
Guys,
is with FinCEN counsel (formerly the Office's best friend at OIA), and has some information
FinCEN has seen and wants to make sure we're aware of.
Thanks,
Co-Chief, Money Laundering and Transnational Criminal Enterprises Unit
Asset Forfeiture Coordinator
United States Attorney's Office
Southern District of New York
Tel:
EFTA00032296


c1: EFTA00032184
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032184.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
1 of?
8/29/19 9:30
8/17/69 MCC BCP
14+ years
Crief Psychologist (11 years)
MDC Brookign staff psuch 03-06
06-08 Gerensic
B.S. anminology
MD counseling (MH)
MA PhD Clinical canxling
Rahway E terry State pnson - psychologist Staff Eyears
Post Doctoran fellowship I year
internship -Miami - inloct MH treatment
FDC program Miami- extemship - cenar wawer- battered wamens
oversignt
Fetensic (3). staff psyand daist (1). Dna above cara., OT spee.
Insures patients are seen, appropriate dounentation
consults an cares as needed
ferensic repons-get Them at an time
reads all unen they are new, Then marc review
reas an repans she signs OAF on
seeing mac patients then namal
7- 3:30 M-F
Intake
PSIQ - all inmates fill it out - MH history as well
as current symptoms They feel
anuming marcea They are seen wl in 14 days
They typically do 7 days, the to do it that aan
care code I -wast significant - not no requirements
2: MH histories controlled mental health procems
seen monthly
3: mar severe -MUST be seen even week
ifnot stable in GP - they 90 to abrovation
-goal is to get Stable -if mey detericate -They
EFTA00032184

=== Page 2 ===
2017
go to a hospital
4: Mar severe than a 3, seen everyday
"pych cbs"
code can be an suicide water (SW)
many times its manipuation (ie: not getting along wl quard,
new cellmate. get out OF jall to hospital)
psychologist meets wl person -Meds, cepina skills
if my do this 2-3x get banped to code 2 to be Met
wl 1x amonth
watch - imminently sucidal
lights It 24/7 constant watan, smock, special blanket
mattress
Inservation -not C every BOP signt
-mere unen she
step program to rece how they do
got there
constant observation, 1:1 all liants
SW can be demmental if an sw longer than needed
get their claining back, mignt act books
consult wl warden, monday maning, friday clorect meeting
Any psychologist can take off S.W., my ao consult sametimes
capt warden misday sand meening
Zassociose w, captain, sup. attences,
Breatwe assistant
warden. DURI afficir
Dept head merting wednesday
only memadane detox BOP prison
#I
intake //
note page 4 -consut
didn't manc anaming on PSIQ had ne not been
he would have gane to GP (Genpop), but due to crimes thagne
best to do intake -
said ne was fine - care code I
after happen court - put an oos precautionary DIC OF what world
svicial
#2 RISK assessment - mad anam he was as obs
no hx OF sucidality or SUD. abose, no major med. cenceras
Polite but annaked no ouch nok Factors
RISE Factors sex ciffender, nian prof crime, only I lungbrother
- didn't appear report depression, diant report anything
EFTA00032185

=== Page 3 ===
(AW)
associate warden
3 of?
#3
suide RSK assessment from
#2 quora "bang alive is fun"
took it genernely
#4 duy 10 -Kept an ons an extra day even Though ne
appeared fine due to housing concerns
Executive stuff notified CF these
associat warden, warden selected Tanaquen (sp?)
wasnt an discussion but believes
its DIC he was a cap wl a lor to 100se
realizes he would be Merc a few weaks corn wl bail
knows he will have a cellmate
doesn't like sho, wants single cell
E acted like Staff wanced For them -ie: planning anead
July 11 - taken OFF obs., at attomey meeting ~ 12 nr/day
spoke to min c attency calf; E was making
he would never be sucidal
saying
Palm Beach attancy
wants oncne calls
wanted brown uniform For aH. meetings wants ree,
- Female officer told
E had 2 calls
possibly officer Days
passed on his concerns TO shu LT.
July 16 - after ball neanna, atterney conference m
ance a month, Or.M does a shu receives
E called For
- treating her like assistant
anastized her bic his needs weren't being met
no psyon concerns, requested kosher diet
July 18 - attempted shu review - didn't see mm bicne
was in attancey conference
got called E was Found wl loose nase wl very
dancer light mancs, unen she tuned around mans were
he was rocking an floor
lett $ duty Bych know - crdered suicide risk assessment
-
For both
0
gaming renersal - and Fartaglect tartaglect hypotheses
3
assourt by cellmate
EFTA00032186

=== Page 4 ===
with
(cenmate) cm
placed on SW
E tells
he doesn't remember what happened
E rold STUN cellmate mea to kill him.
denied suicidanty had FLAUR plans, acter like a big
Fid. wanted to learn, wanted to Fight care
Dr. Pmcry kept min an S.W.
Recerding
next Dan -
- E fearful to return to no cell
Fully 24)
wl cellmate. cm called him pedephine, am
was playing us bedsheet, he full asleep and
woke up snonng
- denied being scicidal, repended bung unhappy WI
ceejal situation, supt well last night, eating, sleeping
dnnking, asking For hygeiene products. legal visits
-
took of S.W., stepped daen to psych. OBS
- allows to nave clomes and materials wl abservation
not any clearer on 3 hypothesis
E is creating dobt to play both sides.
E channing
E attomeys never contacted psychology voicing an opinion
on his mindset or suicidarity
July 25 - Psych cbsewarian contact - done by
E smiling welcome back" - good spirits
E claimed he was banked after being anfrunted by
anunars going an says maybe
can give
nim cocs
continued wl requests complaints
Inave alife and want to qoback to IMIGMY life
Docsn't want to 90 back TO shy
kept on Psuan ons -hor answenna questions
July 24- -
want to see nim again. E wanted trust
again - continues wl complaints, makes jokes
still doesn't answer Dr.m austions about incident
called
on bung Lewish made jace -
no acute symptoms
its against teleron relian to commit suicide
EFTA00032187

=== Page 5 ===
5 of
kiss
E said he doesn't like pain and didn't want to hurt hinself
E had been interacting wl campanions
July 27 - Dr. Emary saw him - -kept an psycn obs.
ICI aiant answer questions still
anxious about returning TO shu b/c he docoit know now he
got the marks
Lt. Doctor Srill didn't have answers as to whether there
was an assant.
the
July 28 -
-same Thing
S#
(stan waking mare merapecticaly provided handats to
no signs in loabooks showng svicidality, participaring
go back to housing
in ugal meetings
Still no contact from E attemens
7129 -
sees E
getting comfertable -wants coundmator TO stay in psych obs
Nanional Sucide Prevantion -Dr. Nagel
7125 email
see - got involved wl cellmate issue
#6
aniting in note pad truina to qer Things done.
E wanted own CPAP lunian has card)
OBS
7139 - quting ready to place him in SHU
psuch
consulted ex. staff an staining extra night in SHU
whot CPAP, or SHU wl CPAP - anox psych CBS.
transmirioned E to SHU next day - Email
7130 - E went to SHU
Dr. m - very important SHU inmates nave cellmates
isclarion
8/9
V privacy
distraction
training an provides asur tavant quantity to Sltu employees
rescue opportunity
All employees 1x year suicide prevention
EFTA00032188

=== Page 6 ===
it: sice
60F7 6
SHU
It days an 2417 observation
-
aid not have conversation wl
captain Sa Closeat mesting -E - really wanted single cell
- all Lts should know cellmate policy are to training,
and them constantly (psyan) reminding Them
There was still a cellmate label on E doct.
Rounds are important to ace an inmate is alone
Rounds - -
awareness
-sne wouldn't be told by afficers blc shes Ex. Staff
- inmates want tell her bic ofices will retalliate
-
is reqimented and reqularly does what she arks
-never heard rounds aren't empleted C niant
will Aug 8 -
didn't know
that would have been a red Flag - he world have
been placed on psuch OBS.
Attomeeps didn't tell Psuch about The will
Female attomey - complaints about water, vending ,nousing
wl a mirder
Aug 8 - SHU neting see sian in sheers. unit members,
Ex staff, atterneys MCC
nothing significant discussed about E.
want to SHU rands TO see e -had cellmate
3
on lower bunk -no usible problems, good spirits
Got Pack # fer phone calls, asked for books
reported getting along wl cuimate
1st attempt to get out on bail
Didn't bic suggest camera room, warden didn't suggest it
wanted THE E to have cellmate
Dr. M has never gane to attorney conference fur any
other patients linmate
EFTA00032189

=== Page 7 ===
1 OFT
lack of cellmate understaffing
3 sucide RSK assessments at is insual
I by judges order
EFTA00032190


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=== Page 1 ===
From: New York Law360 <news-alt@law360.com>
To:
Subject: Greenberg Traurig Can't Avoid Trial In Forgery Suit
Date: Wed, 21 Nov 2018 08:58:00 +0000
Law360 New York
NEW YORK
Law360 Closed For Thanksgiving
Newsletter service will resume on Monday, Nov. 26
Wednesday, November 21, 2018
Follow Law360
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Greenberg Traurig Can't Avoid Trial In Forgery Suit
A state judge in Manhattan on Tuesday rejected a request by Greenberg
Traurig LLP to avoid a trial in a suit by a former Apollo fund manager who
says the firm knowingly used a forged document in litigation against him,
saying all that is left of the case must be decided by a jury in April. Read full
article
Vijay Singh, PGA Settle 5-Year Deer-Antler Doping Saga
Golfer Vijay Singh has settled his lawsuit alleging the PGA Tour acted in bad
faith by suspending him for using a deer-antler supplement that wasn't
actually banned, according to documents filed Tuesday in New York state
court. Read full article
Listen to our new podcast here
Prison An Ignominious End To Gun Atty's Career, Judge Says
LAW FIRMS
A Manhattan federal judge hit gun lawyer John Chambers with a year and a
day in prison Tuesday for bribing a former New York City police sergeant for
Akerman
favors in securing clients' gun permits, saying the sentence marked "an
Allen & Overy
ignominious end to a legal career that started with so much promise." Read
Baker McKenzie
full article
Boehl Stopher
UK Lawyer Gets 20 Months For Decade Of Dodging US Taxes
Brenner Saltzman
A Manhattan federal judge sentenced English lawyer Michael Little to 20
Brune Law PC
months in prison Tuesday for helping the children of a deceased investor
CKR Law LLP
dodge taxes on their $14 million inheritance over a decade and for failing to
Cadwalader Wickersham
pay his own taxes, ruling also that the former Royal Marine lied as he
testified in his own defense. Read full article
Cahill Gordon
Caplin & Drysdale
US Nabs Swiss Banker Wanted In Failed Case Against PE CEO
Casillas Santiago
A Swiss banker wanted for years by U.S. authorities for an alleged market
Clifford Chance
manipulation scheme has been arrested and extradited to the U.S., to face
Covington & Burling
fraud and conspiracy charges in a stock manipulation case that once
targeted private equity CEO Benjamin Wey before it fell apart. Read full
Cravath Swaine
article
DLA Piper
Davis Polk
CONSUMER PROTECTION
Debevoise & Plimpton
Spirit Passengers' Bag-Fee Fraud Suit Preempted
Dewey Pegno
Dykema Gossett PLLC
EFTA00032623

=== Page 2 ===
A New York federal judge on Tuesday tossed a proposed class action
Earthjustice
alleging Spirit Airlines Inc. defrauded consumers by concealing its carry-on
Eversheds Sutherland
bag fees on tickets sold through other online travel agents, saying federal law
Fitch Law Partners
preempts their contract and fraud claims. Read full article
SECURITIES & WHITE COLLAR
Foley & Lardner
Fredericks Peebles
Vending Machine Co. Staff Ask 2nd Circ. To Nix Fraud Raps
Freshfields
A group of former employees of a defunct Long Island vending machine
Fried Frank
company on Tuesday urged the Second Circuit to vacate their convictions for
Gallet Dreyer
defrauding customers by lying about the money-making potential of the
Gibson Dunn
machines, with one worker citing ineffective assistance of counsel. Read full
article
Gleiss Lutz
Goodwin
Convicted Ex-Vereit Exec Attacks Witness' Credibility
Greenberg Traurig
Convicted former Vereit Inc. executive Brian Block angled for a retrial on
Halperin Battaglia
Tuesday, attacking the credibility of a government cooperator who was
Hanamirian Law Firm
offered part of another witness' whistleblower payout - a fact Block says
prosecutors withheld. Read full article
Hermina Law Group
Hogan Lovells
Investor Sues Foot Locker Over $6B Market Cap Drop
Holwell Shuster
A Foot Locker Inc. shareholder filed a derivative suit against the company's
Hughes Hubbard
officers and directors on Tuesday, claiming their actions and
misrepresentations led to a nearly $6 billion drop in the company's market
James Montgomery
capitalization - representing more than half of the company's value - over
Jenner & Block
the course of eight months in 2017. Read full article
Jones Day
Altice Slammed With Stock-Drop Suit After $2.2B IPO
Kaplan Hecker
Katten Muchin
A putative class of investors filed a complaint in New York federal court on
Monday alleging that cable television provider Altice USA Inc. misled them in
Klee Tuchin
the lead-up to the company's $2.2 billion initial public offering before the
Kostelanetz & Fink
stock plunged 43 percent. Read full article
Lankler Siffert
Latham & Watkins
Investcorp Slams Hedge Fund's Bid To Keep $100M Suit Alive
Investment adviser Investcorp lambasted Kortright Capital Partners LP in a
Levi & Korsinsky
heated exchange over whether Investcorp can duck the sole remaining claim
Lewis Brisbois
in a $100 million suit alleging it defaulted on investment promises by pulling
Linklaters
funds out of Kortright ahead of a deal with another party, according to new
Milbank Tweed
filings in New York federal court. Read full article
Morvillo Abramowitz
EMPLOYMENT
Native American Rights Fund
O'Melveny & Myers
Ex-NFL Security Personnel Shorted On OT, Benefits, Suit Says
O'Neill & Borges
A group of former National Football League security personnel filed a
Paul Hastings
proposed class action in a New York federal court Tuesday claiming the
Paul Weiss
league misclassified them as independent contractors as a way to deny them
overtime and benefits. Read full article
Proskauer Rose
Ray Quinney
COMPETITION
Reed Smith
Schiff Hardin
Firm's Antitrust Claims Survive In Interest Rate Swaps MDL
Sepulvado Maldonado
A New York federal judge on Tuesday denied a bid to dismiss fintech firm
Seward & Kissel
trueEX LLC's antitrust claims against 11 banks that allegedly boycotted the
firm's interest rate swaps platform and funneled business to an exchange that
Shearman & Sterling
they operated, finding the allegations mirrored others in the multidistrict
Sher Tremonte
litigation that were allowed to pass through. Read full article
Simpson Thacher
Skadden
Metaswitch Says Rival Telecom Co. Tried To Kill Competition
Metaswitch Networks Ltd., a telecommunications company, filed an antitrust
Steptoe & Johnson LLP
complaint in New York federal court Tuesday alleging that another telecom
Stites & Harbison
intended to eliminate competition among companies that transform landline
Sullivan & Cromwell
The Chandra Law Firm
EFTA00032624

=== Page 3 ===
phone networks through serial acquisitions and exclusionary tactics. Read
Weiser Law Firm PC
full article
White & Case
BANKRUPTCY
Williams & Connolly
Revised Puerto Rico Sales Tax Plan Cleared For Creditor Vote
Willkie Farr
Winston & Strawn
A plan to restructure nearly $18 billion in debt carried by the Puerto Rico
Sales Tax Corp., or COFINA, will go to a creditor vote, the judge presiding
Wollmuth Maher
over the U.S. territory's bankruptcy-like proceedings ruled Tuesday, putting
the agency on track to confirm its debt adjustment scheme by mid-January.
COMPANIES
Read full article »
Altice SA
Altice USA
Provant Creditors File Ch. 11 Clawback Over $2M Transfer
Amazon.com Inc.
The official committee of unsecured creditors of Provant Health has sued a
group of company equity owners, claiming they improperly transferred more
American Airlines Group Inc.
than $2 million from the company to avoid their guaranty obligations. Read
Association on American Indian
full article »
Affairs
BB&T Corporation
BANKING
BC Partners
BNP Paribas
OCC Says NY Still Jumping The Gun On Fintech Charter Suit
Bank of America Corporation
No one has yet applied for or received a fintech charter from the Office of the
Comptroller of the Currency, and that undercuts the latest attempt by New
Barclays Investment Bank
York's financial services regulator to block the charter in court, counsel for the
Center for Biological Diversity
office told a Manhattan federal judge. Read full article »
Citigroup Inc.
Conference of State Bank
TAX
Supervisors
NJ Atty Makes Coy Push For Lead In Danish Tax Fraud MDL
Credit Agricole SA
Deer Consumer Products Inc.
Cryptic concerns about international criminal investigations were not enough
Tuesday to secure New Jersey attorney John M. Hanamirian a leadership
Defenders of Wildlife
role defending hundreds of American pension plans against multidistrict
Deutsche Bank AG
litigation accusing them of cheating Danish tax authorities, a Manhattan
Expedia Inc.
federal judge said in court. Read full article »
Foot Locker Inc.
IMMIGRATION
Garda World Security Corp.
Goldman Sachs Group Inc.
Michael Cohen-Linked Atty Found Guilty Of Asylum Fraud
HighQ Solutions Ltd.
An immigration lawyer linked to President Donald Trump's former attorney
Hooper Holmes, Inc
Michael Cohen was found guilty of lying on more than 100 asylum
Information Security Forum Ltd.
applications to immigration authorities and aggravated identity theft following
a two-week trial, the U.S. Attorney's Office for the Southern District of New
Information Systems Security
York said Monday. Read full article
Association
Investcorp Bank BSC
ENERGY & ENVIRONMENTAL
JPMorgan Chase & Co.
Lehman Brothers Holdings Inc.
States, Dem Legislators Back Monument Suits Against Trump
Man Group PLC
Democratic lawmakers and several states urged a D.C. federal court Monday
McMahon & Associates CPAs
to hear out challenges by environmental groups and tribes to President
Donald Trump's decision to shrink national monuments in Utah, joining a host
Morgan Stanley
of others questioning Trump's authority under the Antiquities Act. Read full
NASDAQ OMX Group Inc.
article
NFL Enterprises LLC
REAL ESTATE & DEVELOPMENT
National Congress of American
Indians
Siemens Accuses NYC Of 'Reckless Conduct' In $143M Suit
National Parks Conservation
Association
New York City owes a Siemens AG unit at least $143 million for "grossly
negligent and reckless conduct" during the construction of a water treatment
National Trust for Historic
plant in the Bronx, the company said in a state lawsuit filed Monday. Read full
Preservation
article
Natural Resources Defense
Council
EFTA00032625

=== Page 4 ===
Real Estate Rumors: Palmcorp, Wells And Goldman, Redwood
New York Post
Palmcorp Development has reportedly landed nearly $14 million in financing
PGA TOUR Inc.
for a project to build single-family homes in Miami, Wells and Goldman are
RBC Capital Markets
said to have loaned a combined $156 million for a New York retail and
Reed Elsevier
residential building, and Redwood Partners has reportedly bought a Long
Beach, California, office campus for $60.5 million. Read full article
Scotiabank Global Banking and
Markets
EXPERT ANALYSIS
Siemens AG
Sierra Club
Emerging Cybersecurity Threats In The Legal Industry
SmartHeat Inc.
Predicting how the cybersecurity landscape will develop is critical for any
Spirit Airlines Inc.
organization wanting to mitigate the risk of the inevitable future attack.
Michael Hall of HighQ Solutions Ltd. discusses five threats to look out for in
TD Securities Inc.
the next 12 months. Read full article
The Bank of New York Mellon
Corp.
LEGAL INDUSTRY
The Priceline Group Inc.
The Wilderness Society
BigLaw Firms Take Cravath's Cue On Holiday Bonuses
Travelocity.com LP
Shortly after Cravath Swaine & Moore LLP's announcement that the firm
Vereit Inc.
would dole out end-of-year bonuses to associates in line with previous years,
a smattering of BigLaw firms pronounced Tuesday that they would follow suit.
WeWork LLC
Read full article
Wells Fargo & Co.
World Anti-Doping Agency
Akerman's Ex-CEO Back In Leadership Role After Shakeup
Akerman LLP's newest chairman and CEO has ended his term after fewer
GOVERNMENT AGENCIES
than 10 months, and his predecessor has stepped in to resume his old post,
European Union
the Florida-based firm announced on Monday. Read full article
Federal Bureau of Investigation
Baker McKenzie Is Strongest Brand In Mainland Europe
Hopi Tribe
Baker McKenzie is the law firm best positioned to take advantage of rising
Internal Revenue Service
legal spending in Europe, according to a survey released Tuesday by London
Navajo Nation
research firm Acritas. Read full article
New York State Department of
Financial Services
Lewis Brisbois Attys Threatened With Jail For Order Breach
Office of the Comptroller of the
A Dallas judge has threatened to jail a representative of security company
Currency
GardaWorld and attorneys at Lewis Brisbois for refusing to turn over GPS
data for a truck involved in a fatal collision. Read full article
Securities and Exchange
Commission
Legal Industry Lags In AI, Machine Learning Use
U.S. Attorney's Office
A recent survey by analytics firm RELX Group found that the legal industry
U.S. Department of Justice
lags behind other industries in utilizing big data, artificial intelligence and
U.S. Supreme Court
machine learning in their work, with legal industry executives also much more
United States Bankruptcy Court for
skeptical of the potential use for AI in their field. Read full article
the Southern District of New York
Law Firm Leaders: Schiff Hardin's Marci Eisenstein
Ute Indian Tribe
Marci Eisenstein, the first woman managing partner of Chicago-based Schiff
Ute Mountain Ute Tribe
Hardin LLP, spoke to Law360 about the changing business of law, the
challenges facing the legal industry and how her firm works to distinguish
itself in an increasingly competitive market. Read full article
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EFTA00032626

=== Page 5 ===
Labor & Employment Associate
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=== Page 1 ===
6
Page 1 of 1
- Epstein
From:
To:
Date:
7/25/2019 1:35 PM
Subject: Epstein
The National Suicide Prevention Coordinator from Central Office, Dr. Nagle, contacted me today about Epstein.
He thought that housing him with another sex offender in SHU would be a good idea. I told him I would speak
with the executive staff about his suggestion. Also,
thought it wise that we keep him down here for a
bit (as is the plan already).
I am heading to the hospital in about a half an hour or so. If you need me for anything, feel free to call my cell
phone
Thank you.
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
fil://C/Users/bop19019/AppData/Local/Temp/XPgrpwise/5D39B00FNYMDOM1NYM. 8/26/2019
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=== Page 1 ===
Just in case you need a synopsis of his activity
Wed 7/31/19
Rec 6:30 = 7:30 a.m.
Court 9:30 - 11:30 am
Thursday 8/1/19
Atty conference beginning 9:00 am - present
Taken off psych ops on Tues 7/30/19. Seen by psych next day as a standard practice. Suicide Risk Assessment (SRA) conducted
today by Dr.
Findings indicate he is psychologically stable. Per Dr.
SRA was initiated because Epstein returned from
court W a note indicating suicidal tendencies. see attachment
Associate Warden (O)
FCI Estill
100 Prison Road
Estill, SC 29918
CONFIDENTIAL
SDNY_00009170
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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re
- Epstein
Date: Tue, 09 Jul 2019 14:02:13 +0000
Hi
Are you still free for a call?
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza
I
4th Floor
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Sunday, July 7, 2019 at 10:19 PM
To:
Cc:
)"
)"
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:
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
Subject: Re:
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
EFTA00032700

=== Page 2 ===
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may
be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before
you meet with Ms
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
212.637.2415
From:
Sent: Saturday, July 06, 2019 22:55
To:
-
Subject:
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
- Epstein
Mr.
My former partner, Alan Ross, represented
, prior to his passing in
2018. Agen
served Ms.
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
EFTA00032701

=== Page 3 ===
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
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
Miami Florida 33129
t.
www.crimlawfirm.com
EFTA00032702


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=== Page 1 ===
To:
From:
Sent:
Sun 7/21/2019 10:00:07 AM
Subject: Lieutenant's log and daily activities report for Saturday, July 20, 2019.
TEXT.htm
LIEUTENANT'S LOG 07-20-2019.docm
Daily Activities Report 7-20-2019.docx
Lieutenant's log and daily activities report for Saturday, July 20, 2019.
Lieutenant
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, N.Y. 10007
CONFIDENTIAL
SDNY_00008967
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=== Page 1 ===
Thanks again
Epstein will need a POFU tomorrow for crisis.
>>>
7/10/2019 10:14 AM >>>
Psy.D.
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Office:
CONFIDENTIAL
SDNY_00009750
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=== Page 1 ===
From: Laura Woods <laurawoods579@gmail.com>
To:
"
)"
Subject: Ghislane MAXWELL
Date: Fri, 27 Sep 2019 11:49:59 +0000
Ghislane looks very much like Melania Trump.
Respectfully submitted,
Laura Isabel Woods
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=== Page 1 ===
From:
To:
Subject: RE: quick question re: MCC stuff
Date: Tue, 27 Jul 2021 14:30:36 +0000
Sure, on my cell
From
Sent: Tuesday, July 27, 2021 10:13 AM
To
Subject: quick question re: MCC stuff
Hey
- I have a quick question for you re: MCC stuff and Epstein guards case, as it relates to Tartaglione. Let me
know when you have a second to chat. Thanks.
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
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=== Page 1 ===
From:
"
To:
)"
Cc:
)"
(USANYS)"
,
)"
Subject: Re:
Date: Wed, 21 Apr 2021 18:45:58 +0000
We are pretty much open on all of those dates. Preferably a 12 noon start or later works best.
On Apr 21, 2021, at 14:23,
)
wrote:
Team,
is available for a follow-up interview by video on the following dates: May 3, 4 (before 2pm), 5, 6, 12, 13 or
14. Please let me know what works for everyone.
Thanks,
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=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
July 24, 2019
REPLY TO
ATTN OF:
,
M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
/
Executive Assistant
Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for July 23, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported Control panel inoperative for ES/GS Main
Door/Fire Exit doors. Inner Gate inoperative. Fire Watch continues.
Call for assistance on 9-South. I/M Epstein #76318-054 placed on
Suicide Watch.
Day Watch Shift:
Lt.
reported Fire Watch in progress. Correctional
assignments 3
Officer, 10-South #2 vacated, due to, a
shortage of staff.
Evening Watch Shift:
Lt.
reported Fire Watch in progress. Correctional
assignments SHU #4, due to, a shortage of staff.
CONFIDENTIAL
SDNY_00009010
EFTA00033644

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M Burnett #76254-054 at Local Hospice w/USMS Guards
NEW ADMISSIONS TO MCC New York:
Cooper #85972-054
RELEASED FROM MCC NEW YORK:
Cooper #85972-054
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
None
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
SIS Office
Central Tool Room
2 Sallyport
Chapel
Recreation
Education
Facilities Shops
Rear Gate
MISSING EQUIPMENT INVENTORY FORM:
2 Sallyport
Roof Recreation
Rear Gate
THE FOLLOWING LEAVE WAS UTILIUZED:
FURLOUGH: 00
LWOP: 01
ANNUAL LEAVE: 06
ADMIN LEAVE: 00
SICK LEAVE: 06
COMP TIME: 00
OFFICIAL TIME: 01
TRAINING: 01
SUSPENSION: 01
GLYNCO: 00
FFLA: 00
LWOP (M) : 04
FMLA: 00
TOA: 01
COP: 02
EPO: 00
AWOL: 09
TRAVEL: 00
ADVANCE LEAVE: 00
CONFIDENTIAL
SDNY_00009011
EFTA00033645

=== Page 3 ===
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 23
Hours = 166.30
E-1 COMPTIME:
Number of staff = 03
Hours = 16.45
60-Q OVERTIME (USM MEDICAL) :
Number of Staff = 00
Hours = 00.00
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
07-23-2019 / 12:00 AM
UNIT B-A: 26
UNIT E-N: 88
UNIT E-S: 86
UNIT G-N: 76
UNIT G-S: 91
UNIT H-A: 00
UNIT I-N: 89
UNIT K-N: 92
UNIT K-S: 139
UNIT Z-A: 74
UNIT Z-B: 05
TOTAL:
776
CONFIDENTIAL
SDNY_00009012
EFTA00033646


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Subject: Notes from 11/25/20 Call with GM Counsel
Date: Wed, 25 Nov 2020 18:05:21 +0000
11/25/20 Call with Chris Everdell and Bobbi Sternheim
Have call scheduled with MDC legal counsel; hope we can raise with them whatever issues come out of
conversation
Most productive to understand what specific asks you have of the Warden so we can convey them and see what
can be done
Sternheim
Think you know how much appreciate you intervening; don't think it necessarily is your job or our job, that's why
helpful to hear from warden himself
If warden is one making decision, better if he reports to the court
Would rather at least try to come up with particular list
Sternheim
In history of dealing with MDC/MCC, only time progress made when court makes someone from MDC/MCC go to
court
Hope that you made request and judge issued order to meet and confer immediately will be enough to get things
done
Sternheim
Clear that they cannot put her in general population; that is not an unwise decision; will be a problem for her
personally for a variety of reasons, and I don't just mean physically
Gap between not being in general population (GP) and being in the situation that she is in; certain things that GP
inmate is allowed that she is not
GP: Lights out at 9:30; GM is locked in at 8 pm
GP: not continually searched when moved; GM: searched to the point of invasion; understand she is
searched every time she goes from one space to another; variety of searches, seems excessive - including
strip searches after visits, open mouth, fingers through hair, touching her body
Understand that stopped putting fingers in her mouth
Routine to do strip search after visit
Sternheim
Know they did COVID test and required that move mask to look in her mouth
Redundancy to over management of GM
Now she has her cup in her room, successful in getting a toothbrush (before your help she had for one day)
Entitled to every opportunity barring congregation with other inmates that is afforded to inmates in GP
b/c of COVID - allowed outside of cell only for 3 hours a day (to shower in shared shower, shared call, computer,
television)
EFTA00032004

=== Page 2 ===
GM has shower to herself, phone to herself, computer, laptop, TV to herself; in MDC view, client is getting more
than every other inmate during COVID; she is out of her cell for 13 hours
Sternheim
Difficulty with that statement is that flags how deficient treatment of inmates is
Equal treatment is create situation where put her in a general population
Given amount of discovery in this case if she had to share computer, would go to trial in 2023
Got her accommodation b/c she has significant amount of discovery to review
Sternheim
Not going to deny that given more time to review than other inmates are
Understand I can't just say give her everything, make exactly same as GP, but there are clients in GP that have
own computer, tablets, and allowed to review discovery endless hours a day
Don't think that's right; understand that
If 13 hours not enough, then let us know what will be
Everdell
Constant surveillance; camera on her all times; woken up every 15 minutes to make sure breathing; treated as if
on suicide watch; disruptive to her health and to her ability to concentrate on preparing a defense
Going forward, things to address sounds like normalizing amount of searches to be consistent with what other
inmates experience and minimizing amount of disruption, particularly to her sleep at night, consistent with what
other inmates experience
Surveillance - understanding is that second camera is meant to capture the same area in case there is a
malfunction in BOP camera system; camera in area outside in wall or ceiling that already captures and records
same area
Sternheim
Why is camera facing me and my client in a visiting room?
Understand that there are no cameras inside the room, but cameras outside the room showing who goes in and
out
Sternheim
That is a distinction; camera pointed into the room
Pass up the ask that camera not be pointed anywhere that cameras not already pointed
Everdell
Other inmates have handheld camera following them around 24 hours a day? Includes lawyers/legal visits;
Understanding that there is not another inmate with backup camera system; reason for backup is that sometimes
BOP camera fails and decision made to have backup camera that covers same area covered by normal area
Happy to go back to MDC and say should not record anything not recorded by normal cameras
Sternheim
3 officers watching 2 people in room where no one else, and camera pointed on us
Everdell
Already in a cage, not particularly pleasant; add stress of having handheld camera pointed directly at you;
someone has camera up in your face, all the time; very invasive
If cameras already recording, then why is it needed if just redundant; causes real disruption and distress in some
ways
Sternheim
Invasive, maybe they will read lips; going far in my example; BOP overusing their authority
EFTA00032005

=== Page 3 ===
What I'm taking away from this is that unless MDC stops entirely with second camera, that want warden brought
before Judge Nathan
Sternheim
Want explanation directly from Warden why this is being done and why being done to GM; why degree of
surveillance and searches on GM
Any searching and surveillance beyond what is done to other inmates
Why locked in at 8 pm?
Sternheim
Not saying GP is good for her; not using day room which would eliminate a lot of these issues; but have elected
not to do that
Let warden explain why
From MDC perspective, client gets more benefits than many inmates, gets special treatment given all access she
has
Sternheim
Given other treatment, where she is virtually in solitary confinement; don't view giving her more time to review
discovery that ameliorates fact that she is being treated differently
Client is first had where did not go to SHU, but went to own wing of jail where has access to computer, TV, etc.,
that would have in GP; treated differently than someone who would ordinarily go to protective custody
Everdell
Feel like there has to be some recognition from the Government that GM finds herself in position she is in b/c of
who she is;
To hear that getting perks, from defense side, starts b/c she is put in solitary
Not fair to say she is better off than other inmates
In solitary, recorded 24 hours a day - b/c of who she is
Want to make sure she is in her chair at trial b/c of what happened with Epstein
Sternheim
Advocates of our client; putting you in role for being lawyer for BOP which is not correct
Let warden say what he needs to say before the judge
To recap, areas would like to see improved, surveillance - asking that second camera be removed entirely? Or is
there any modification that would be acceptable to you?
Sternheim
don't have firm answer; don't think when meeting with her or every step of the way
Will convey to BOP reducing use of camera and certainly not pointing into room where attorney meetings take
place
Other issue is amount of searching - reduced to amount of searching that other inmates experience
Waking her up at night - ask that do nothing differently than what do to check on other inmates at night
Everdell
One other point on searches; when moves from isolation cell to day room to do discovery review, etc., that
involves a bunch of searches too; our understanding was plan was for her to be housed in day room
Need to keep her in certain room when would limit movement and searches if housed in day room
Will raise day room again
Sternheim
Not allowed to maintain any food that she doesn't eat
Think same for everyone; so that don't make hooch
EFTA00032006

=== Page 4 ===
How much time she needs to review discovery? We understand a lot of discovery; have been over-inclusive in
what we have given you; we have given you material that we don't anticipate using at trial, that doesn't relate to
your client; 1.2 million documents is searchable to help expedite review
If think client needs more than 13 hours a day, please let me know; when pushed MDC to allow for time to
review discovery, have been responsive
Everdell
Only get extension cord after laptop dies; don't know if has gotten better
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:
EFTA00032007


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=== Page 1 ===
From: Laura Menninger <lmenninger@hmflaw.com>
To:
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Fri, 02 Apr 2021 21:35:30 +0000
Inline-Images: image001.jpg
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
EFTA00032465

=== Page 2 ===
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
EFTA00032466

=== Page 3 ===
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
EFTA00032467

=== Page 4 ===
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
EFTA00032468

=== Page 5 ===
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
EFTA00032469

=== Page 6 ===
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00032470

=== Page 7 ===
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
EFTA00032471

=== Page 8 ===
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
EFTA00032472

=== Page 9 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00032473

=== Page 10 ===
From:
)
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
EFTA00032474

=== Page 11 ===
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
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EFTA00032475


