# docs_fts_content

c1: EFTA00014876
c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014876.pdf
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=== Page 1 ===
From:
)"
To:
Subject: draft letter re witness order
Date: Tue, 23 Nov 2021 23:07:24 +0000
Attachments: 2021-11-27,_GM,_Government_anticipated_witness_order.docx
Draft attached. Let me know when would be good to talk through the order. I decided to include the order that I think is
most likely, rather than the order of proof order (which is premised on the fastest imaginable version of the trial).
EFTA00014876


c1: EFTA00016884
c2: DataSet 8
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016884.pdf
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=== Page 1 ===
LAST WILL AND TESTAMENT
OF
JEFFREY E. EPSTEIN
I, JEFFREY E. EPSTEIN, of Little St. James Island, St. Thomas, United States Virgin Islands, being of
sound mind, do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils
made by me.
FIRST:
A.
I direct my Executor to pay from my estate all expenses of my
last illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts
duly proven and allowed against my estate.
B.
I direct my Executor to pay from my estate, as
compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty
Thousand Dollars ($250,000) to each Executor upon the completion of probate of my estate. No
Executor shall receive any other compensation for serving as Executor hereunder; provided, however,
that my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and
liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other agents
hired by my Executor, and my Executor shall not be liable therefor individually.
C.
I direct my Executor to pay from my estate the Federal
and state transfer taxes described in Paragraph B(1) of Article SEVENTH.
D.
I direct my Executor to pay from my estate all expenses
of storing, insuring, packing, shipping and delivering my tangible personal property in accordance with
Article SECOND.
SECOND: I give, bequeath and devise all of my property, real and personal,
wherever situated, which I won at my death or of which I have the power to dispose after the payments
and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2014
Trust (the "Trust") created under that certain Trust Agreement (the "Trust Agreement") dated November
, 2014, as the same may be amended from time to time, to be held in accordance with the provisions
comprising the Trust Agreement at the time of my death.
THIRD:
A.
I appoint DARREN K. INDYKE, DAVID MITCHELL and
JAMES E. STALEY to be the Executors of this Will. If any one or more of my Executors fails to qualify
or ceases to act, I appoint LAWRENCE H. SUMMERS as successor Executor. I authorize the last acting
Executor to designate his successor as Executor.
B.
If my estate must be administered in whole or in part in
any jurisdiction other than the state or territory of my domicile at the date of my death and if my
Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor of my
estate designated in Paragraph A of Article THIRD provided that he is able and willing to serve in such
jurisdiction. If no Executor or successor Executor is able and willing to serve in such jurisdiction, my
Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be
made by written instrument delivered to such successor Executor.
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C.
No bond or other security shall be required of any
Executor in any jurisdiction.
D.
Any Executor may resign in the manner provided for by
the governing statutes of the state or territory having jurisdiction of the administration of my estate or, in
the absence of such statutory guidance, by filing a written notice of resignation with the Court having
jurisdiction of the administration of my estate. Any Executor who resigns shall not be entitled to any
compensation hereunder for any services rendered as Executor prior to his resignation.
E.
My Executor shall not be accountable or responsible to
any person interested in my estate for the manner in which my Executor in good faith exercises or
declines to exercise any discretionary authority or power of my Executor. My Executor shall not be liable
for any loss or depreciation in value occasioned by reason of any negligence, error or mistake of
judgment in entering into any transaction, in making any sale or investment, in continuing to hold any
property or by reason of any action or omission, whether by my Executor or any other fiduciary, unless
my Executor has acted in bad faith. In the absence of proof by affirmative evidence to the contrary and
affirmative evidence of my Executor acting in bad faith, each Executor shall be deemed to have acted
within the scope of my Executor's authority, to have exercised reasonable care, diligence and prudence
and to have acted impartially as to all interested persons. An Executor shall not be liable for the acts or
defaults of another Executor.
FOURTH:
The following provisions shall apply to my estate and to my Executor,
except as is otherwise specifically provided in this Will:
A.
My Executor has the entire care and custody of all
assets of my estate. My Executor has the power to do everything my Executor in good faith deems
advisable without necessity of any judicial authorization or approval, even though but for this power it
would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My
Executor shall exercise my Executor's best judgment and discretion for what my Executor believes to be
in the best interests of the beneficiaries hereunder. If more than two Executors are empowered to
participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law,
a majority of such Executors shall be empowered to make such decision.
B.
Except as otherwise provided herein, my Executor shall
have the power:
(1) to enter upon and take possession of the assets
of my estate and collect the income and profits from such assets, and to invest and reinvest such assets
in real, personal or mixed assets (including the common trust funds of a corporate fiduciary) or in
undivided interests therein without being limited by any present or future investment laws;
(2)
to retain all or any part of the assets of my
estate (without regard to the proportion that any one asset or class of assets may bear to the whole) in the
form in which such assets were received or acquired by my Executor;
(3)
to sell or dispose of, exchange, transfer, invest
or loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such
sums or upon such terms as to payment, security or otherwise as my Executor determines, either by
public or private transactions;
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(4)
to buy and sell options, warrants, puts, calls or
other rights to purchase or sell (collectively "options") relating to any security or securities, regardless of
whether such security or securities are then held by my Executor, and whether such options are
purchased or sold on a national securities exchange, and to exercise with respect to such options all
powers which an individual owner thereof could exercise, including, without limitation, the right to allow
the same to expire;
(5) with respect to oil, natural gas, minerals, and all
other natural resources and rights to and interests therein (together with all equipment pertaining
thereto) including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other
oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or
otherwise, or alone or jointly with others as partner, joint tenant, or joint venture in any other
noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay delay rentals, lease
bonuses, royalties, overriding royalties, taxes, assessments, and all other charges; (c) to sell, lease,
exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and interests; (d) to
surrender or abandon, with or without consideration, any or all of such rights and interests; (e) to make
farm-out, pooling, and unitization agreements; (f) to make reservations or impose conditions on the
transfer of any such rights or interests; (g) to employ the most advantageous business form in which
properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships,
mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all such rights and
interests; (h) to produce, process, sell or exchange all products recovered through the exploitation of
such rights and interests, and to enter into contracts and agreements for or in respect of the installation
or operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests
in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any or
all of the powers set forth herein to the operator of such property; and (k) to employ personnel, rent
office space, buy or lease office equipment, contract and pay for geological surveys and studies, procure
appraisals, and generally to conduct and engage in any and all activities incident to the foregoing
powers, with full power to borrow and pledge in order to finance such activities; together with the
power to allocate between principal and income any net proceeds received as consideration, whether as
royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other
natural resources;
(6)
to hold all or any part of the assets of my estate
in cash or in bank accounts without the necessity of investing the same;
(7)
to improve, repair, partition, plat or subdivide
all or any part of the assets of my estate;
(8)
to litigate, defend, compromise, settle, abandon
or submit to arbitration on such terms and conditions as my Executor determines; to propose or accept a
compromise with respect to any claims in favor of or against my estate or the assets of my estate;
(9)
to loan or borrow money in such amounts and
upon such terms and conditions as my Executor determines, assume such obligations or give such
guarantees as my Executor determines, for the purpose of the acquisition, improvement, protection,
retention or preservation of the assets of my estate, or for the welfare of the beneficiaries of my estate;
(10) to carry on for as long and in such manner as
my Executor determines any business enterprise in which I owned any interest at my death, either
individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such business
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enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or undertake any
other extraordinary corporate transaction relating to such business enterprise;
(11) to vote in person or by proxy any and all stock
or securities and to become a party to any voting trusts, reorganization, consolidation or other capital or
debt readjustment of any corporation, association, partnership, limited liability partnership, limited
liability company or individual with respect to stocks, securities or debts held by my estate;
(12) except as provided in paragraphs B(19) and
B(20) of this Article FOURTH, to enter into any good faith transactions with my Executor individually
or with any corporation, partnership or other entity in which my Executor has an ownership interest;
(13) to lease, mortgage, pledge, grant a security
interest in or otherwise encumber all or any part of the assets of my estate for any term of years whether
or not beyond the duration of my estate (including, without limitation, any such action for the benefit of
any of the beneficiaries of my estate);
(14) to abandon any property of my estate, real or
personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or
protecting; to abstain from the payment of taxes, water rents or assessments and to forego making
repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax sale or
other proceedings or to convey any such property for a nominal consideration or without consideration so
as to prevent the imposition of any liability by reason of the continued ownership thereof;
(15) to elect the mode of distribution of the proceeds
payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual
retirement plan, insurance contract or annuity contract pursuant to the terms of such plan;
(16) to allocate, in my Executors discretion, any
adjustment to basis provided to my estate under the provisions of Federal and state law with respect to
property comprising my estate, without any obligation to make a compensatory adjustment among the
beneficiaries hereunder on account of such allocation;
(17) to conduct any audit, assessment or
investigation with respect to any asset of my estate regarding compliance with any law or regulation
having as its object protection of public health, natural resources or the environment ("Environmental
Laws"); to pay from the assets of my estate to remedy any failure to comply with any Environmental
Law (even to the exhaustion of all of the assets of my estate); and, as may be required in my Executor's
judgment by any Environmental Law, to notify any governmental authority of any past, present or future
non-compliance with any Environmental Law; and
(18) to sell to the Trustee under the Trust Agreement
any stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under
the Trust Agreement even though the same person or persons occupy the office of the Executor of my
estate and the Trustee under the Trust Agreement.
(19) No executor shall directly or indirectly buy or
sell any property for the estate from or to himself, or from or to his relative, employer, employee,
partner, or other business associate.
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(20) No executor shall lend estate funds to himself, or
to his relative, employer, employee, partner, or other business associate.
C.
Except as otherwise provided herein, my Executor shall
have the power:
(1)
to employ agents, attorneys-at-law, consultants,
investment advisers (to whom my Executor has discretion to delegate my Executor's investment
authority and responsibility), other executors and other fiduciaries in the administration of my Executor's
duties; to delegate to such persons, or to one or more of my Executors, the custody, control or
management of any part of my estate as my Executor determines and to pay for such services from the
assets of my estate, without obtaining judicial authorization or approval;
(2)
to delegate, in whole or in part, to any person or
persons the authority and power to (a) sign checks, drafts or orders for the payment or withdrawal of
funds, securities and other assets from any bank, brokerage, custody or other account in which funds,
securities or other assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell,
transfer or deliver, or purchase or otherwise acquire, any and all property, stocks, stock warrants, stock
rights, options, bonds or other securities whatsoever, (c) gain access to any safe deposit box or boxes in
which my assets or assets of my estate may be located or which may be in the name of my Executor and
remove part or all of the contents of any such safe deposit box or boxes and release and surrender the
same, and (d) take any other action that my Executor may have the power to take with respect to my
estate and the property thereof; no person or corporation acting in reliance on any such delegation shall
be charged with notice of any revocation or change of such delegation unless such person or corporation
receives actual notice thereof;
(3)
to pay any property distributable to a
beneficiary under a legal disability, without liability to my Executor, by paying such property (a) to such
beneficiary, (b) for the use of such beneficiary, (c) to a legal representative of such beneficiary appointed
by a court or if none, to a relative for the use of such beneficiary, or (d) to a custodian for such
beneficiary designated by my Executor;
(4)
to distribute to any of the beneficiaries of my
estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or
disproportionate shares of assets or undivided interests in assets among all of such beneficiaries;
(5) to have evidence of ownership of any security
maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to
deposit funds in any bank or trust company; to carry in the name of my Executor or the nominee or
nominees of my Executor and with or without designation of fiduciary capacity, or to hold in bearer
form, securities or other property requiring or permitting of registration; and to cause any securities to
be held by a depository corporation of which an Executor is a member or by an agent under a
safekeeping contract; provided, however, that the books and records of my Executor shall at all times
show that such investments are part of my estate;
(6)
to renounce and disclaim, in whole or in part,
and in accordance with applicable law, any assets, interests, rights or powers (including any power of
appointment) which are payable to (or exercisable by) me or my estate, which are includible in my estate
or Gross Estate or over which I have any right, title, interest or power; and
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(7)
to make, execute and deliver any and all such
instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of
my Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and
all other powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my
estate.
D.
In connection with any insurance policy or annuity on
the life of an Executor which is included in my estate, such Executor shall not participate in the decision
to exercise or not exercise any fiduciary power in connection with any incidents of ownership for such
policy or annuity, including, without limitation, any decision to continue, assign, terminate or convert
such policy or annuity or to name the beneficiary of such policy or annuity.
E.
An Executor hereunder may by a written notice
delivered to the other Executor (or Executors) decline to participate in the decision to exercise or not
exercise any fiduciary power granted by this Will or by law.
F.
If an Executor is not empowered (because of a conflict
of interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any
fiduciary power granted by this Will or by law, then the remaining Executor or Executors shall be
empowered to make such decision. If no Executor is empowered to participate in such decision, then the
successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing to act
shall be empowered to make such decision. If no Executor or successor Executor is empowered to
participate in such decision, my Executor may designate a successor Executor to serve as Executor of my
estate who shall be empowered to make such decision but shall have no other power or authority of my
Executor. Such designation shall be by written notice delivered to such successor Executor.
G.
(1)
Except as otherwise specifically provided
herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and
disbursements in accordance with sound trust accounting principles and shall have discretion to allocate
receipts and disbursements when the treatment is uncertain under applicable laws or generally accepted
accounting principles in the judgment of my Executor.
(2)
Except as otherwise specifically provided in
this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset
of my estate as income distributable to or for the benefit of any beneficiary entitled to distributions of
income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any
financial instrument originally issued or acquired at a discount equal to the amount which (a) has
previously been characterized as ordinary income for income tax purposes or (b) will be characterized as
ordinary income for income tax purposes in the year of such sale, as income for trust accounting
purposes.
FIFTH:
Where a party to any proceeding with respect to my estate has the same
interest as a person under a disability, it shall not be necessary to serve legal process on the person under
a disability.
SIXTH:
If any beneficiary under the Trust shall in any way directly or indirectly
(a) contest or object to the probate of my Will or to the validity of any disposition or provision of my
Will or of the Trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in
the institution or prosecution of, any action, proceeding, contest, objection or claim for the purpose of
setting aside or invalidating my Will or the Trust or any disposition herein or therein or provision hereof
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or thereof, then I direct that (a) any and all provisions in the Trust for such beneficiary and his issue in
any degree shall be null and void and (b) my estate, whether passing under my Will or the Trust or
pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree
had all failed to survive me.
SEVENTH:
A.
As used herein:
(1)
The term "Executor" of a person's estate means
all persons or entities who occupy the office of executor, administrator, personal representative, or
ancillary administrator while such persons or entities occupy such office, whether one or more persons or
entities occupy such office at the same time or times, and includes any successor or successors to that
office. The term "Trustee" means all persons or entities who occupy the office of Trustee under the Trust
Agreement while such persons or entities occupy such office, whether one or more persons or entities
occupy the office of Trustee at the same time or times, and includes any successor Trustee or Trustees. A
reference to a person's estate or probate estate means that person's estate which is subject to probate
administration. A reference to a person's Will means such person's Last Will and Testament and any
Codicil or Codicils thereto.
(2)
The term "IRC section" means a section of the
Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal
Revenue law, as in effect as of the date of my death.
(3)
A reference to any tax also includes any interest
or penalties thereon. A reference to a person's "Gross Estate" means such person's gross estate as finally
determined for purposes of computing such person's federal estate tax.
(4)
Whenever the singular number is used, the
same shall include the plural, and the masculine gender shall include the feminine and neuter genders.
B.
(1)
The Federal and state transfer taxes which my
Executor shall be obligated to pay pursuant to Paragraph C of Article FIRST shall consist of all Federal
and state estate, inheritance, succession, and similar taxes (including any Federal or state generation-
skipping transfer tax) imposed upon my probate estate or by reason of my death in respect to all assets
which pass under this Will or the Trust Agreement. Subject to Paragraph B(2) of this Article, all Federal
estate taxes with respect to assets not passing under this Will or the Trust Agreement (such assets are
referred to as the "Apportionment Assets") and any applicable state estate taxes with respect to the
Apportionment Assets shall be apportioned among all persons interested in the Apportionment Assets.
My Executor shall make reasonable efforts to collect all Federal estate taxes and state estate, inheritance,
succession and similar taxes allocable to the Apportionment Assets from the recipients of the
Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(1), my
Executor has discretion, but is not required, to pay all or part of such taxes allocable to the
Apportionment Assets. To the extent my Executor pays such taxes allocable to the Apportionment
Assets, my Executor shall seek reimbursement for such taxes from the recipients of the Apportionment
Assets. My Executor shall not be personally liable for any of such taxes if my Executor is unable, with
reasonable efforts, to collect payment (or reimbursement) from any recipient of any Apportionment
Assets for any or all of such taxes allocable to such assets.
(2)
My Executor has discretion to direct the Trustee
of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated
to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction
delivered to the Trustee under the Trust Agreement. Any taxes which my Executor directs the Trustee
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under the Trust Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement
as provided under the Trust Agreement.
C.
Except as otherwise specifically provided in this Will, a
bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to the
contrary.
D.
To the extent that the distribution to the Trustee under
the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my
property, real and personal, wherever situated, after the payments and distributions provided in Article
FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, be to held in
trust under this Will in accordance with the provisions comprising the Trust Agreement at the time of my
death, which provisions are incorporated in this Will by reference.
IN WITNESS WHEREOF, I have duly executed this Will the 18 th day of November,
2014.
JEFFREY S E. EPSTEIN
The foregoing written instrument was on the date thereof, signed, published and
declared by the Testator therein named as the Testator's Will in the presence of us and of each of us,
who, at the Testator's request, in the Testator's presence and in the presence of each other, have
subscribed our names as witnesses thereto.
CRds residing at
St Thomas, VI 00802
Irone Drensa Well residing at
St. Thomas, VI 00802
We, JEFFREY E. EPSTEIN, CECILE DE JONGH and, JEANNE BRENNAN the Testator and the
witnesses, respectively, whose names are signed to the foregoing instrument, having been sworn,
declared to the undersigned officer that the Testator, in the presence of the witnesses, signed the
instrument as his Will, that he signed, and that each of the witnesses, in the presence of the Testator and
in the presence of each other, signed the Will as a witness.
JEFFREY CRA E. EPSTEIN
Jeanne Buxnan Wulrachs
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TERRITORY OF THE UNITED STATES VIRGIN ISLANDS )
)ss:
DIVISION OF ST. THOMAS AND ST. JOHN
)
Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally known to
me or who has produced
as identification, and by CECILE DE JONEH
, a
witness who is personally known to me or who has produced
as identification, and
JEANNE BRENNAN WIEBRACHT a witness who is personally known to me or who has produced
as identification, on November18, 2014.
Erika A. Kellerhals
Sworn to before me this 18th day of
Notary Public LNP-11-14
November, 2014.
Commission Expires 05/29/18
St. Thomas/St. John, USVI
P Notary Public
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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: FW: Monday
Date: Mon, 18 Oct 2021 04:12:01 +0000
Attachments: Government_MIL_v6.docx
Hey
- I've citechecked sections IV through the end, so there are sections I-III left. Hopefully
+ another para
or intern will confirm the quotes, etc., for the whole document, but I think one of us should lay eyes on the key cases in
each section. If you have bandwidth, would you mind doing either section I or sections II and III?
From:
Sent: Monday, October 18, 2021 12:08 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Monday
Amazing! Thank you!
I've attached a draft for citechecking. We'll probably make some small tweaks before finalizing the table of contents and
authorities. This is pretty long, so if there's another paralegal who can help pitch in, feel free to rope them in too. I'll see
if I can find an intern who can help.
Thanks!
From:
(USANYS) [Contractor]
Sent: Sunday, October 17, 2021 8:55 PM
To:
)
Cc:
is
(USANYS)
Subject: Re: Monday
Hi
For sure, I'll definitely have time to tackle this tomorrow. Just send over anything I'll need.
Thanks,
Sent from my iPhone
On Oct 17, 2021, at 8:19 PM,
wrote:
Hey
I hope you're having a nice weekend!
Our motions in limine for Maxwell are due tomorrow. Do you have bandwidth tomorrow to help finalize the
document? We definitely need help making a table of authorities and table of contents, and if you have time, we'd love
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=== Page 2 ===
help doing a citecheck of the document too.
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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From:
To:
Subject: Fwd: [EXTERNAL] Good morning
Date: Tue, 23 Nov 2021 14:08:10 +0000
Sent from my iPhone
Begin forwarded message:
From: "Katersky, Aaron"
Date: November 23, 2021 at 9:02:35 AM EST
To:
Subject: [EXTERNAL] Good morning
Nice note about the trial
For a preview piece I am going to write about Maxwell's most prominent public accuser,
, not
being part of this case; no charges based on her allegations and not expect to be a witness for Gov. And also
; not being on witness list;
Assume no comment but any issues there?
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From:
)"
To:
(USANYE)"
Subject: FW: Richardson
Date: Wed, 21 Aug 2019 17:09:32 +0000
Embedded:t_c_with_counsel_for_Bill_Richardson,_re:_JE_case.msg
This is so, so frustrating.
From:
)
Sent: Wednesday, August 21, 2019 13:09
To:
(USANYS)
is
is
Cc:
(USANYS)
Subject: RE: Richardson
Hey I spoke to
and
about this, but just to keep everyone in the loop, I did talk to Jeff on Sunday and did
(what I thought was) a fairly standard witness / subject / target distinction, noting we didn't have sufficient information to
put him into the witness or target boxes, and that we didn't currently intend to subpoena him or request to speak with
him based on the investigation at this time. So I didn't specifically say he was a subject, but I noted the three categories
and said we didn't have enough information for witness or target. I also said that there weren't specific allegations that
we need to hear his side of at this time, and I think my intended point was conveyed, which was that we weren't currently
asking for anything from him-not that there are no allegations at all, which obviously there are, publicly. I did not say
that there is no allegation that the government is actively investigating; I just would never say to an attorney what we are
or aren't investigating. In any event, my contemporaneous notes are attached, I typed and sent them less than ten
minutes after our conversation, which lasted all of four minutes. I'm really sorry for any difficulties this causes us.
After talking with
about it, I also just spoke to Jeff and expressed my view that the statement does not fully
accurately reflect our conversation, and that our press office could respond to questions about it or he could clarify, and
he said he would get back to me with how he proposed to address the discrepancies.
From:
(USANYS)
Sent: Wednesday, August 21, 2019 12:05
To:
is
V.
Cc:
(USANYS)
Subject: FW: Richardson
Has anyone talked to Jeff Brown and is this accurate?
From:
(USANYS)
Sent: Wednesday, August 21, 2019 12:01 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: Richardson
Richardson has given the following statement to the press, true and accurate?:
EFTA00014372

=== Page 2 ===
Governor Bill Richardson offered his assistance in the Jeffrey Epstein investigation - through his lawyer, Jeff Brown of
Dechert LLP - to the US Attorney for the Southern District of New York. In response to this offer, Mr. Brown was informed
by the Assistant US Attorney responsible for the case that Governor Richardson is neither a target, subject, nor witness in
the case and that there is no allegation against Governor Richardson that the government is actively investigating.
"It's fair to conclude that the federal prosecutors investigating this matter do not believe the Governor participated in or
witnessed the criminal activity Jeffrey Epstein is alleged to have committed," said Mr. Brown.
Governor Richardson hopes that the investigation continues so that Epstein's victims can finally have their day in court
and see the justice they deserve.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00014373


c1: EFTA00015532
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015532.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 12, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the defendant's Motion for
Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its
Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge
Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A).
PRELIMINARY STATEMENT
The defendant is a serial sexual predator who is charged with abusing underage girls for
years. A grand jury has returned an indictment alleging that he sexually exploited dozens of
minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a
registered sex offender designated by New York State in the highest category of risk to reoffend,
despite unsuccessfully attempting to have that classification lowered. And any doubt that the
defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered
hundreds or thousands of nude and seminude photographs of young females in his Manhattan
mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime
involving a juvenile.
The defendant also faces substantial evidence of his guilt, founded on the corroborated
testimony of numerous victims, and this case presents the very real possibility that he will go to
prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which
remain largely concealed from the Court. He also has a history of obstruction and manipulation
of witnesses, including, as detailed herein, as recently as within the past year, when media reports
about his conduct reemerged. And he continues to show a shocking lack of understanding of the
gravity of the harm he has perpetrated, including through the minimization of his conduct and
casual disparagement of victims in his arguments.
Against this backdrop of significant-and rapidly-expanding-evidence, serious charges,
and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions
that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant
EFTA00015532

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 2
law, seeks to diminish and demean the harm caused to the many victims of the defendant's
appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no
condition or combination of conditions will reasonably assure the appearance of the defendant as
required and the safety of the community. Rather than even attempting to address the grave risks
of releasing a defendant with extraordinary financial resources and a history of abusing minors,
the defendant instead proposes a bail package that amounts to little more than a barely-secured
bond masquerading as a 14-point plan. The Court should reject the defendant's application and
order him detained pending trial.
Among other things, the proposed bail package contemplates the defendant pledging as the
principal security a property that has already been identified by the Government as subject to
forfeiture upon the defendant's conviction, and which therefore is of no value as collateral. His
proposed global waiver of extradition is unenforceable, and even if enforceable would be little
comfort to victims forced to wait additional years while the defendant is located and returned to
this country. The promise to "deregister or otherwise ground" his private jet is meaningless given
his wealth and ability to easily secure other means of travel. The two co-signers he proposes only
further highlight his minimal community ties, including his lack of any family in or near the
District. Electronic monitoring would merely give the defendant less of a head start in fleeing-
and does not guard against the risk of him endangering victims in the very home where he has
continued to hoard nude images of young women and girls. And the private security force he
proposes to guard his gilded cage, a proposal already rejected by this Court in similar
circumstances, simply reinforces the obvious fact that the defendant should be housed where he
can be secured at all times: a federal correctional center.
The defendant faces a presumption of detention, Pretrial Services has recommended
detention, and victims of the defendant seek his detention. Because there are no set of conditions
short of incarceration that can reasonably assure the appearance of the defendant or reasonably
protect the community from the dangers he poses if released, the Court should order him detained.
BACKGROUND
As previously set forth, a federal grand jury in this District returned an indictment (the
"Indictment") charging the defendant with violating Title 18, United States Code Section 1519,
and conspiracy to commit the same.
As charged by the grand jury, the facts giving rise to those counts involve a years-long
scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens
of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in
cash, in at least two different states. Victims were initially recruited to provide "massages" to the
defendant, which would be performed nude or partially nude, would become increasingly sexual
in nature, and would typically include one or more sex acts, including groping and direct or indirect
contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant
actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He
paid these victim-recruiters hundreds of dollars for each additional girl they brought to him,
creating a network of underage victims for him to exploit in New York and Palm Beach.
EFTA00015533

=== Page 3 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 3 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 3
The defendant, through counsel, continues to evidence a complete lack of appreciation for
the gravity of the offenses with which he is charged.¹ As an initial matter, there can be no plausible
suggestion that the allegations against the defendant involve isolated or aberrational conduct; they
involve repeated, regular acts of sexual abuse committed over a period of many years. And
following the defendant's prior conviction, as described previously by the Government, the
defendant continued to maintain at least hundreds and possibly thousands of nude photos of young
subjects. The defendant's victims in this case, often particularly vulnerable girls, were as young
as 14 years old when he abused them. The defendant knew he was abusing minors, including
because victims told him directly they were underage. And he preyed on his victims habitually
and repeatedly-day after day, month after month, year after year.
The defense calls these disturbing alleged acts "simple prostitution."² Mag. Tr. 12:12; see
also D. Tr. at 6:15-19 ("This is basically the Feds today
redoing the same conduct that was
investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That
characterization is not only offensive but also utterly irrelevant given that federal law does not
recognize the concept of a child prostitute-there are only trafficking victims-because a child
cannot legally consent to being exploited. Defense counsel's repeated assertion that the
Government's case is infirm because no threats or coercion are alleged-e.g., Mag. Tr. at 12
("There was no coercion. There were no threats. There was no violence."), 17 ("there was no
coercion. There was no intimidation. There is no deception."); Release Motion at 2 ("There are
no allegations
that he forced, coerced, defrauded, or enslaved anybody
")-is equally
irrelevant because the offense with which the defendant has been charged requires no such proof.
See, e.g., United States V. Afyare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that $ 1591(a)
criminalizes the sex trafficking of children (less than 18 years old) with or without any force, fraud,
or coercion, and it also criminalizes the sex trafficking of adults (18 or older), but only if done by
force, fraud, or coercion.").
Far more important, the defense has already effectively conceded that the Government will
be able to present evidence of the actual primary elements of the charged offense-i.e., that the
defendant engaged in sex acts for money with girls he knew were underage. See Release Motion
at 2. On this record, the Government agrees with Pretrial Services that the defendant should be
detained pending trial. He poses a tremendous risk of flight and a danger to the community, and
he cannot overcome the statutory presumption in favor of detention in this case.
I Such arguments are unsurprising from a defendant who previously compared himself to a "person
who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey
Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an
"offender," the financier told The Post yesterday. 'It's the difference between a murderer and a
person who steals a bagel. "); Philip Weiss, The Fantasist, NY Magazine (2007) ("It's the Icarus
story, someone who flies too close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.").
2 "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019;
"D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019.
EFTA00015534

=== Page 4 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 4 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 4
ARGUMENT
The Government respectfully submits that the defendant cannot overcome the statutory
presumption in favor of detention in this case for the following reasons, among others:
I.
Victims Seek Detention
Pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be
reasonably heard at certain public proceedings in the district court, including proceedings
involving release. 18 U.S.C. $ 3771(a)(4). Consistent with that requirement, the Government has
been in contact with victims and counsel identified through this investigation in connection with
the argument regarding bail.
Multiple victims and/or their counsel have asked the Government to seek detention (and to
inform the Court of their views in that respect) for multiple reasons. First, they believe that the
defendant's continued detention is necessary under the CVRA's right to be reasonably protected
from the accused. 18 U.S.C. $ 3771(a)(1). They have specifically conveyed to the Government
that they would be fearful for their safety if the defendant were released. For the reasons articulated
herein, the Government believes those concerns to be well-founded.
Additionally, certain victims have asked the Government to advise the Court that they are
specifically concerned about the defendant's proposal to be released even if under conditions that
included home detention and full-time private guards. They believe it would be unfair to victims
of a wealthy defendant, like Epstein, if he were to be given greater freedoms than others would be
in similar circumstances, and that such an arrangement would be inconsistent with their rights.
They specifically asked the Government to advise the Court that they believed such an arrangement
could result in harassment and abuse by the defendant. 3
II.
The Defendant's Proposal Does Nothing to Mitigate His Flight Risk
Each of the relevant factors to be considered as to flight risk-the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant-
counsel strongly in favor of detention, and the defendant's proposed package would do nothing
whatsoever to mitigate those risks.
A. Defendant Proposes No Infringement Upon His Ability to Use his Vast Wealth to Flee
It might not be immediately apparent to a reader of the Release Motion that the defendant
is extravagantly wealthy and worth, according to records relating to the defendant recently
obtained by the Government from a financial institution ("Institution-1"), more than $500 million.
3 The Government is aware of at least one additional attorney for a victim who has publicly stated
that her client supports the pretrial detention of the defendant. The Government is unaware of any
victim who has expressed support for the defendant being granted pretrial release on bail.
EFTA00015535

=== Page 5 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 5 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 5
Indeed, while the defendant has still not filled out a financial affidavit, under penalty of
perjury, in connection with his application for bail, his token effort to account for his finances
makes painfully clear the need for detention. The defendant reports having an extraordinary
amount of money in both total assets and cash or cash-equivalent holdings. And while the
defendant repeatedly represents in his Release Motion that his assets are "in the United States,"
there is absolutely nothing in the defendant's minimal financial submission to verify that.
Indeed, and as discussed further below, even assuming the defendant's assets are presently
in the United States, nothing in the proposed package would prevent the defendant from
transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The
defendant is an incredibly sophisticated financial actor with decades of experience in the industry
and significant ties to financial institutions and actors around the world. He could easily transfer
funds and holdings on a moment's to places where the Government would never find them so as
to ensure he could live comfortably while a fugitive.
But perhaps most important, even were the defendant to sacrifice literally all of his current
assets, there is every indication that he would immediately be able to resume making millions or
tens of millions of dollars per year outside of the United States. He already earns at least
$10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin
Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to
stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do
whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of
extradition.
That the defendant faces up to 45 years of incarceration on the current counts with which
he is charged provides the motive for him do so and is another significant factor in assessing the
risk of flight. See United States V. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of
the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence,
already robust less than a week ago when the Indictment was unsealed, is growing stronger by the
day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions,
have identified themselves to the Government as having been victimized by the defendant when
they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government
has discovered and seized a significant volume of photographs of nude and seminude young
women and girls in the defendant's Manhattan residence, and is in the process of reviewing dozens
of electronic discs that contain still more such photos. And dozens of individuals have called the
Government in recent days to convey information regarding the defendant and the allegations
4 As noted in the Government's Detention Memo, the defendant is a frequent traveler and regularly
travels to and from the United States, including approximately more than 20 flights in which he
traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature
further demonstrates a significant risk of flight. See, e.g., United States V. Anderson, 384 F. Supp.
2d 32, 36 (D.D.C. 2005).
5 The Government's review of these materials, seized earlier this week, remains ongoing.
EFTA00015536

=== Page 6 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 6 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 6
contained in the Indictment. All this in less than a week, and all in addition to an Indictment that
already alleges the existence of dozens of victims in New York and dozens of victims in Florida.
B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention
The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to
secure his release" are neither highly restrictive nor amply sufficient. Rather, they are effectively
standard conditions of home confinement, monitoring, and bond unsecured by the defendant's
assets-broken out into 14 pieces. The Government will address the most concerning and salient
elements of the defendant's proposal below.
1. Lack of Meaningful Bond Security
The defendant proposes that the Court accept his Manhattan mansion as the primary
security for a personal recognizance bond of an indeterminate amount, to be co-signed by the
defendant's brother and a friend. Release Motion at 4. This is plainly insufficient.
As an initial matter, and as noted above, the defendant's Manhattan mansion has been
identified in the Indictment as subject to forfeiture because it is alleged to have been used to
commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C.
$ 1594(c)(1). Because the defendant would thus be likely to lose that property following a
conviction, it provides no value whatsoever as collateral. See 18 U.S.C. $ 3142(g)(4) ("In
considering the conditions of release described
the judicial officer
shall decline to accept
the designation, or the use as collateral, of property that, because of its source, will not reasonably
assure the appearance of the person as required."). And while the defendant offers to also pledge
his private jet as additional collateral, there is absolutely no reason to assume that the defendant
would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net
worth of more than $500 million, by his own admission recently sold a second plane and thus
presumably has cash on hand to replace the posted aircraft without difficulty if need be.
Nor does the proposed security of properties owned by two identified co-signers
meaningfully change the calculus. As further described below, the defendant provides no
information about the value or equity of the property of his brother, Mark (the "Palm Beach
Property"), or the significance of that property in the context of his brother's own net worth.6
Similarly, the defendant provides no details regarding the "investment interests" of his friend Mr.
Mitchell, nor any reason to believe the loss of those "interests" would be meaningful to Mr.
Mitchell, let alone the defendant. More generally, given the defendant's proffered net worth, the
defendant could easily make his co-signers whole - and even reward them - were he to flee.
The proposed security, in sum, should give the Court little comfort the defendant would
appear in Court if released on bail.
6 In fact, the defendant's own submission makes clear that the Palm Beach Property is not his
brother's exclusive residence and that his brother lives elsewhere for half of the year.
EFTA00015537

=== Page 7 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 7 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 7
2. Co-Signers, Moral Suasion, and Ties to the Community
The dearth of detailed financial information about the defendant himself, much less his
brother or friend, further shows the hollowness of the proposal. The Court cannot possibly
evaluate whether there would be any incentive whatsoever for those the two proposed co-signers
to exercise moral suasion over the defendant-or whether, as noted above, the defendant could
easily compensate them, perhaps many times over, for any loss they incurred through the
defendant's flight from justice. The defendant provides no information about his brother other
than that he lives half the year in the home he purportedly would pledge, and even less information
about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of
decades," and his "close personal friend." Release Motion at 4, 9. Their willingness to "guarantee"
his appearance, Release Motion at 9, is meaningless in the absence of such information.
Moreover, the notion that any individual co-signer could meaningfully secure a bond for
this defendant strains credulity. Given the defendant's wealth and his extraordinary risk of flight,
any bond for this defendant would assuredly have to be in the hundreds of millions of dollars to
even be claimed to be sufficient to guard against the risks posed by the defendant's release. The
defendant offers no reason to believe any co-signers could meaningfully sign such a bond, much
less these two particular individuals, which is yet another reason the proposed package is patently
insufficient.
3. The Defendant's "Consent" to Extradition is Unenforceable and Impractical
The defendant's offer to sign a so-called "consent" to extradition provides no additional
reassurance whatsoever. As an initial matter, the Government would need to find and re-arrest the
defendant before such a waiver would even come into play. Moreover, even assuming the
Government could locate and apprehend the defendant, numerous courts have recognized that such
purported waivers are unenforceable and effectively meaningless because any defendant who signs
such a purported waiver and then flees will assuredly contest the validity and/or voluntariness of
the waiver, and will get to do so in the jurisdiction of his choosing (i.e., the one to which he chose
to flee). See, e.g., United States V. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y.
Dec. 23, 2016); United States V. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug.
3, 2015); United States V. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah
Aug. 27, 2013); United States V. Cohen, No. C 10-00547, 2010 WL 5387757, at *9 n.11 (N.D.
Cal. Dec. 20, 2010); United States V. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United
States V. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000); United States
V. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). The Department of Justice's Office of
International Affairs is unaware of any country anywhere in the world that would consider an
anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a
jurisdiction with which the United States does not have an extradition treaty.
Beyond being impossible to guarantee, extradition is typically a lengthy, complicated and
expensive process, and the possibility that it would be successful neither provides any real
deterrent to the defendant's incentive to flee nor any measure of justice to the victims who would
be required to wait years for his return.
EFTA00015538

=== Page 8 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 8 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 8
4. Home Confinement and Electronic Monitoring Provide No Assurance
The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the
Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio
frequency bracelet is farcical because neither one is useful or effective after it has been removed.
At best, home confinement and electronic monitoring would reduce his head start should he decide
to cut the bracelet and flee. See United States V. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1
(E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention
with electronic monitoring "at best
limits a fleeing defendant's head start"); see also United
States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United
States V. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (same); United States V. Benatar, No. 02
Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same).
5. Private Security is Inadequate, Unfair, and Impractical Here
The defendant also proposes the use of a private security force to march him to and from
court under the threat of deadly force. This proposal should be rejected.
At the outset, it is far from clear that private jail, which seeks to replicate the conditions of
a government-run detention facility in the defendant's home, is a condition of "release" that
implicates the Bail Reform Act. "[T]here is a debate within the judiciary over whether a defendant,
if she is able to perfectly replicate a private jail in her own home at her own cost, has a right to do
so under the Bail Reform Act and the United States Constitution." United States V. Valerio, 9 F.
Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never
directly addressed this issue. See United States V. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007)
("The government has not argued and, therefore, we have no occasion to consider whether it would
be "contrary to the principles of detention and release on bail' to allow wealthy defendants 'to buy
their way out by constructing a private jail." (citations omitted)). Indeed, a decision by this Court
reasoned that "the very severe restrictions" in the private jail proposal presented to him did "not
appear to contemplate 'release' so much as it describes a very expensive form of private jail or
detention." United States V. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016).
Courts have long been troubled by private jail proposals like the defendant's which, "at
best "elaborately replicate a detention facility without the confidence of security such a facility
instills." United States V. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States V. Gotti,
776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F.
Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use
force against defendant should he violate the terms of his release, and the questions over whether
the guards can or should be armed, underscore the legal and practical uncertainties-indeed, the
imperfections-of the private jail-like concept envisioned by defendant, as compared to the more
secure option of an actual jail."). A private security firm simply cannot replicate the controlled
environment of a federal correctional facility, in which, typically, all of the needs to the prisoner
can be attended to without placing the prisoner in the community at large; the defendant's proposed
private jail arrangement would have the effect of permanently placing him in just such a high-
flight-risk circumstance. The risk of a public escape attempt while in the community and involving
EFTA00015539

=== Page 9 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 9 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 9
armed private guards attempting to stop the defendant, potentially by force-rather than the
defendant being in the environment of a federal facility-also greatly magnifies the danger of the
defendant's flight to the public. See United States V. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y.
2019). "This is why, as the Government correctly notes, federal prisoners should be detained in
facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sabhnani,
493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force
may need to be used to assure defendant['s] presence at trial [s]uch a conclusion would, in fact,
demand a defendant's detention")).
The Second Circuit has held it is not legal error "for a district court to decline to accept,"
as "a substitute for detention," a defendant hiring private security guards to monitor him. United
States V. Banki, 369 Fed. App'x 152, 153-54 (2d Cir. 2010). In the same decision, the Second
Circuit noted that it was "troubled" by the possibility of "allow[ing] wealthy defendants to buy
their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g.,
United States V. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *3 (S.D.N.Y. July 19, 2013)
("it is contrary to underlying principles of detention and release on bail that individuals otherwise
ineligible for release should be able to buy their way out by constructing a private jail, policed by
security guards not trained or ultimately accountable to the Government, even if carefully
selected" (quoting Borodin V. Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001))); Valerio, 9
F. Supp. 3d at 293-94 (E.D.N.Y. 2014) ("There is nothing in the Bail Reform Act that would
suggest that a defendant (or even, hypothetically, a group of defendants with private funding) has
a statutory right to replicate or construct a private jail in a home or some other location.").
The defendant's payment of his guards also raises the conflict of interest inherent in having
the defendant having extraordinary influence over a private security company tasked with guarding
him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani,
356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the
appearance of a defendant, noting a "clear conflict of interest-private prison guards paid by an
inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant
"was outside of his apartment virtually all day, every weekday; was visited by a masseuse for a
total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in
Chinatown with his private guards in tow"); see also United States V. Tajideen, 17 Cr. 046, 2018
WL 1342475, at *5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further
noting: "While the Court has no reason to believe that the individuals selected for the defendant's
security detail would intentionally violate federal law and assist the defendant in fleeing the Court's
jurisdiction, it nonetheless is mindful of the power of money and its potential to corrupt or
undermine laudable objectives. And although these realities cannot control the Court's ruling, they
also cannot be absolutely discounted or ignored.").
Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard
proposal is unreasonable because it helps to foster inequity and unequal treatment in favor of a
very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016
WL 3681423, at *13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast
financial resources to construct his own "private prison,' the Court is not convinced "disparate
treatment based on wealth is permissible under the Bail Reform Act") (quoting United States V.
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Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 10 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 10
Bruno, 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) (""Even if Defendant had the financial capacity
to replicate a private jail within his own home, this Court is not convinced that such a set of
conditions would be sufficiently effective in this case to protect the community from Defendant,
or that such disparate treatment based on wealth is permissible under the Bail Act.")); Borodin,
136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of
detention and release on bail that individuals otherwise ineligible for release should be able to buy
their way out by constructing a private jail, policed by security guards not trained or ultimately
accountable to the government, even if carefully selected.").
If the defendant's appearance can only be assured through use of round-the-clock guards,
the defendant belongs in a federal detention center, not released under bail conditions that
effectively create a private prison of one, using guards to be paid by the defendant himself. It is
frankly outrageous for the defendant to suggest that preventing him from using his vast wealth to
duplicate a private prison that cannot control, monitor, and contain him consistent with the
requirements of the Bail Act would cause him to somehow "bear a special disadvantage." Release
Motion at 12 n.9. Indeed: "What more compelling case for an order of detention is there than a
case in which only an armed guard and the threat of deadly force is sufficient to assure the
defendant's appearance?" Zarrab, 2016 WL 3681432, at *12 (quoting United States V. Valerio, 9
F. Supp. 3d at 295).
III.
The Defendant Provides No Assurance He is Not a Danger to the Community and a
Risk to Obstruct Justice
A. Danger to the Community
In the first instance, the defendant's argument that 14 years without a criminal conviction
eliminates "any danger presumption" should be rejected. Were that the case-which is certainly
is not-a lack of criminal record for any defendant would automatically rebut the presumption
applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States V.
Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was
"not so compelling as to defeat the presumption or to manifest clear error in the district court's
determination that no combination of release conditions
could reasonably assure against
dangerousness and the risk of flight"). Moreover, here, the defendant not only has a criminal
record, but has been convicted of a sex crime involving a minor.
But the ongoing and forward-looking danger posed by the defendant is further
demonstrated by the defendant's maintenance of a substantial collection of photographic trophies
of his victims and other young females in his mansion, as discovered by the Government through
its search warrants. As indicated in the Detention Memo, the many discs found in the defendant's
residence included those with hand-written labels including the following: "Young [Name] +
[Name]," "Misc nudes 1," and "Girl pics nude." Not surprisingly, the Government has found that
such discs contain photographs of sexually suggestive photographs of fully- or partially-nude
females appearing to be underage.
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=== Page 11 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 11 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 11
B. Danger to Obstruct Justice
The defendant has also already demonstrated a willingness to use intimidation and
aggressive tactics in connection with a criminal investigation. Far from being "musty," Release
Motion at 6 n.6, the defendant's past behavior in connection with being investigated for sexually
abusing children is the best predictor of his likely incentives and activities in connection with being
charged with sexually abusing children. For example, in the incident the defendant now claims
was not attributable to or authorized by him, the contemporaneous police report indicates that
pressure tactics were at the very least coordinated closely with individuals in the defendant's orbit.
See Palm Beach Police Report (the "Police Report") (Ex. B). According to the Police Report, the
parent of one of the defendant's victims was driven off the road by a private investigator. The
Police Report provides further information regarding victim and witness threats and intimidation
reported against an individual who was directly in contact with an assistant of the defendant,
followed "immediately" by a call to that same individual from a phone number associated with the
defendant's businesses and associates.
Separately, and in addition, there are also extensive allegations of obstruction and
tampering in connection with civil lawsuits brought against the defendant following his 2008
conviction. See Doe V. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31.
Moreover, police reports suggest that an associate of Epstein's was offering to buy victims' silence
during the course of the prior investigation. Specifically, one victim reported that "she was
personally contacted through a source that has maintained contact with Epstein," who "assured
[the victim] that she would receive monetary compensation for her assistance in not cooperating
with law enforcement." Indeed, the victim reported having been told: "Those who help him will
be compensated and those who hurt him will be dealt with." See Palm Beach Police Report
(Ex. C).
And Epstein's efforts to influence witnesses continue to this day. As in the past, within
recent months. he paid significant amounts of money to influence individuals who were close to
him during the time period charged in this case and who might be witnesses against him at a trial.
By way of background, on or about November 28, 2018, the Miami Herald began publishing a
series of articles relating to the defendant, his conduct, and the circumstances of his prior
conviction and the non-prosecution agreement ("NPA"). Records obtained by the Government
from Institution-1 appear to show that just two days later, on or about November 30, 2018, the
defendant wired $100,000 from a trust account he controlled to an individual named as a possible
co-conspirator in the NPA. The same records appear to show that just three days after that, on or
about December 3, 2018, the defendant wired $250,000 from the same trust account to another
individual named as a possible co-conspirator in the NPA and also identified as one of the
defendant's employees in the Indictment. Neither of these payments appears to be recurring or
repeating during the approximately five years of bank records presently available to the
Government. This course of action, and in particular its timing, suggests the defendant was
attempting to further influence co-conspirators who might provide information against him in light
of the recently re-emerging allegations
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=== Page 12 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 12 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 12
IV.
The Defendant Raises Legal Arguments Not Relevant Here
Finally, the defendant raises certain legal arguments he contends he will litigate at the
appropriate stage and which he further suggests mitigate in favor of bail. None is meritorious, and
certainly none should give the Court any comfort whatsoever that the defendant would, if granted
bail, refrain from fleeing so he could attempt to vindicate himself via dubious legal strategies.
Nevertheless, the Government will address the defendant's arguments briefly in turn.
A. The Non-Prosecution Agreement Does Not Preclude Prosecution
As an initial matter, as the Court itself noted at the parties' initial appearance earlier this
week, and as the defendant appears to concede, the instant Indictment charges conduct well beyond
the scope of the NPA - that is, alleged conduct that occurred here in New York and involving New
York based victims. D. Tr. 6-8; Release Motion at 2. For present purposes, that alone is sufficient
to put this issue to rest, because even assuming the defendant were to mount a meritorious
challenge to the NPA, he would still have to stand trial on Count Two of the Indictment and
additional charges brought based on New York conduct.
But more generally, the reasons the defendant can be prosecuted in the Southern District
of New York-or anywhere else outside the SDFL-are manifold. The language of the NPA
overwhelmingly refers to the SDFL, and the core terms and text of the agreement are limited to
the SDFL. The prefatory language states: "THEREFORE, on the authority of R. Alexander
Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for
these offenses shall be deferred in favor of prosecution by the State of Florida.' The final
paragraph of the prefatory language also states, among other things, that after fulfilling the terms
of the agreement, "no prosecution for the [sex abuse] offenses set out on pages 1 and 2 of this
Agreement, nor any other offenses that have been the subject of the joint investigation by the
Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that
arose from the Federal Grand Jury investigation will be instituted in this District."
In its terms section, the NPA further states that Epstein's signature "is not to be construed
as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense" as
to any victim whose identity was not disclosed by SDFL to Epstein, as provided for in the NPA,
and additionally states that neither Epstein's signature nor any resulting waivers or civil
settlements "are to be construed as admissions or evidence of civil or criminal liability or a waiver
of any jurisdictional or other defense as to any person." These provisions show the parties
contemplated possible criminal prosecutions in other jurisdictions and/or based on victims not
initially identified in the Florida investigations (whether in Florida or elsewhere). The final
substantive paragraph of the NPA states that "Epstein hereby requests that the United States
Attorney for the Southern District of Florida defer [...] prosecution."
It is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office
does not, unless otherwise stated, bind another." United States V. Prisco, 391 F. App'x 920, 921
7 All emphases relating to the NPA are added unless otherwise specified.
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=== Page 13 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 13 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 13
(2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the
district in which the plea is entered unless it affirmatively appears that the agreement contemplates
a broader restriction.") (citing United States V. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per
curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not
abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal
prosecutor agrees that 'the Government' will dismiss counts of an indictment
might be thought
to bar the United States from reprosecuting the dismissed charges in any judicial district unless the
agreement expressly limits the scope of the agreement
However, the law has evolved to the
contrary."). "The mere use of the term 'government' in the plea agreement does not create an
affirmative appearance that the agreement contemplated barring districts other than the particular
district entering into the agreement." United States V. Salameh, 152 F.3d 88, 120 (2d Cir. 1998)
(citations and internal quotation marks omitted); see also United States V. Brown, No. 99-1230,
2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement,
reiterating the holding of Annabi and noting that it applies "even if the plea agreement purports to
bind 'the Government" or the "United States") (summary order); United States V. Bruno, 159 F.
Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the
phrase 'United States' shows an intent to bind all United States Attorney's Offices. Rather, the
plea agreement covers only Defendant's liability in the SDFL.").⁸
In sum, this issue is a distraction that has little relevance to the bail determination and does
nothing to address the defendant's risk of flight or mitigate the danger he poses to the community.
B. The Defendant Wrongly Argues the Statute Does Not Apply to His Sex Trafficking
Next, the defendant wrongly argues that the "principal conduct" giving rise to the charges
is his payment of underage girls for sex acts, and that such conduct could not possibly fall under
the charged statutes. As the defendant implicitly concedes, Release Motion at 14, this is an issue
for a motion to dismiss. Nevertheless, the defendant's argument is incorrect for two reasons.
First, although the defendant undoubtedly participated on the demand side of the crime, he
was also instrumental on the supply side given his role in recruiting and causing others to recruit
additional victims. He organized, funded, and perpetuated a sex trafficking scheme in two states,
including with co-conspirators. The fact that he did so for his own eventual and frequent sexual
gratification does not vitiate his role in enticing and recruiting victims, consistent with the elements
of the offense with which he is charged. The defendant was the leader of a sex-trafficking
enterprise, not a mere consumer.
8 This analysis similarly extends to a non-prosecution agreement. See United States V. Laskow,
688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is
an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices
of the United States Attorney that are not parties to the agreement. This position is at odds with
the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement
unless a defendant can affirmatively establish that a more expansive interpretation was
contemplated.") (citing Annabi, 771 F.2d at 672).
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=== Page 14 ===
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 14 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 14
Second, he is also wrong on the law. Courts have found that Section 1591 applied to both
suppliers and consumers of commercial sex acts. See, e.g., United States V. Jungers, 702 F.3d
1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral
sex from an underage girl and explaining: "The sole issue raised on appeal is whether '[t]he plain
and unambiguous provisions of 18 U.S.C. $ 1591 apply to both suppliers and consumers of
commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the
defendant, Fierro V. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied
heavily on the statutory interpretation undertaken by two district courts in the District of South
Dakota, United States V. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and
United States V. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which
were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven
years since Fierro has been decided, it does not appear to have been cited by a single other court.
Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or
customers. See United States V. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions
under Section 1591 of both the buyer and seller of a child); United States V. Cook, 782 F.3d 983
(8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness
if applied to purchasers); United States V. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D.
Mo. Dec. 7, 2009) ("contrary to defendant's argument, 18 U.S.C. $ 1591 clearly applies to those
who attempt to purchase underage sex, not merely the pimps of actual exploited children") (citing
United States V. Roberts, 174 F. App's 475 (11th Cir. 2006) (in which defendant was convicted
under sections 1591(a) and 1594(a) even though no actual children were involved)).
CONCLUSION
As set forth above, the defendant's proposed bail package is insufficient and insubstantial.
Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual
and concerning confluence of factors in this case, including the defendant's extraordinary wealth,
demonstrated willingness to interfere with victims and witnesses, continued possession of lewd
photographs of young females, and both the incentive and means to flee prosecution.
Very truly yours,
GEOFFREY S. BERMAN
United A
By:
/
/
Assistant United States Attorney
Southern District of New York
Tel: (212) 637-2415/2225/2324
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
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=== Page 15 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 1 of 10
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 8, 2019
VIA ECF
The Honorable Henry Pitman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Pitman:
The Government respectfully submits this letter in advance of the bail hearing scheduled
for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should
order that the defendant be detained pending trial; he cannot meet his burden of overcoming the
presumption that there is no combination of conditions that would reasonably assure his continued
appearance in this case or protect the safety of the community were he to be released.
As set forth below, the charges in this case are exceptionally serious: the defendant is
alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years,
and he now faces a potentially massive prison sentence predicated on substantial and multifaceted
evidence of his guilt. In light of the strength of the Government's evidence and the substantial
incarceratory term the defendant would face upon conviction, there is an extraordinary risk of
flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private
planes capable of international travel, and his significant international ties. Indeed, the arrest of
the defendant occurred when he arrived in the United States on his private jet after having returned
from a multi-week stay abroad.
Finally, and as detailed herein, the Government has real concerns-grounded in past
experience with this defendant-that if allowed to remain out on bail, the defendant could attempt
to pressure and intimidate witnesses and potential witnesses in this case, including victims and
their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger
to the community, including some of its most vulnerable members, and a significant risk of flight.
The defendant thus cannot overcome the statutory presumption that detention is appropriate in this
case, and the Court should order that he be detained pending trial.
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=== Page 16 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 2 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 2
BACKGROUND
A. Overview
On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed
indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors,
in violation of 18 U.S.C. $ 1591, and one count of conspiracy to commit sex trafficking of minors,
in violation of 18 U.S.C. § 371.
As charged by the grand jury, the facts underlying the charges in the Indictment arise from
a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the
defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he
paid the victims hundreds of dollars in cash.
He undertook this activity in at least two different locations, including his mansion in
Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the
"Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in
similar ways. Victims were initially recruited to provide "massages" to the defendant, which
would be performed nude or partially nude, would become increasingly sexual in nature, and
would typically include one or more sex acts, including groping and direct or indirect contact with
victims' genitals. The defendant paid his victims hundreds of dollars in cash for each separate
encounter.
Moreover, the defendant actively encouraged certain of his victims to recruit additional
girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying
these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this
fashion, the defendant created a vast network of underage victims for him to exploit, in locations
including New York and Palm Beach.
The defendant's victims were as young as 14 years old when he abused them. Many of his
victims were, for various reasons, often particularly vulnerable to exploitation. The defendant
intentionally sought out-and knew that he was abusing-minors. Indeed, in some instances, his
victims expressly told him they were underage before or during the period in which he abused
them.
In creating and maintaining a network of minor victims whom he abused, the defendant
worked with others, including employees and associates who facilitated his exploitation of minors
by, among other things, contacting victims and scheduling their sexual encounters with the
defendant, both in New York and in Florida.
B. The Defendant
Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant
and through his direction of others, including certain of his employees, to further facilitate his
rampant abuse of underage girls.
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=== Page 17 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 3 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 3
As has been widely reported, the defendant is extraordinarily wealthy, and he owns and
maintains luxury properties and residences around the world, including in Manhattan, New York;
Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a
private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary
residence in the United States. His mansion in Manhattan alone-a multi-story townhouse
reported to be one of the largest single residences in all of Manhattan, which previously housed a
school and which he owns through an LLC-has been valued at approximately $77 million.
Entities controlled by the defendant also own at least two private jets in active service, at least one
of which is capable of intercontinental travel.
As described further below, the defendant possesses three active United States passports,
and his international connections and travels are extensive. For example, in addition to
maintaining a residence in Paris, France, as described above, in the past 18 months alone, the
defendant has traveled abroad, via private jet, either into or out of the country on approximately
more than 20 occasions.
C. The Prior Florida Investigation
In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in
connection with allegations that he had committed similar sex offenses against minor girls. The
investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for
the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews
with victims based in the Palm Beach area, including some of the alleged victims relevant to Count
One of the instant Indictment.
In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in
connection with the conduct at issue in that investigation, which the non-prosecution agreement
identified as including investigations into the defendant's abuse of minor girls in the Palm Beach
area. The Southern District of New York was not a signatory to that agreement, and the defendant
was never charged federally.² In June 2008, the defendant pled guilty in state court to one count
of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation
of prostitution, a felony. As a result, the defendant was designated as a sex offender with
registration requirements under the national Sex Offender Registration and Notification Act.
1 The non-prosecution agreement, further discussed below, was entered into at the conclusion of
the SDFL investigation and did not purport to cover any victims outside of the State of Florida.
As noted above, the instant Indictment expressly alleges the existence of dozens of victims who
were abused in this District in addition to dozens of victims who were abused in Florida.
2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the
Second Circuit that absent an express provision to the contrary in the agreement, one District is
not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's
Office in another district. See page 6, infra.
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=== Page 18 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 4 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 4
ARGUMENT
I.
Applicable Law
Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to
order a defendant's detention pending trial upon a determination that the defendant is either a
danger to the community or a risk of flight. 18 U.S.C. $ 3142(e) ("no condition or combination of
conditions would reasonably assure the appearance of the person as required and the safety of any
other person and the community"). A finding of risk of flight must be supported by a
preponderance of the evidence. See, e.g., United States V. Jackson, 823 F.2d 4, 5 (2d Cir. 1987);
United States V. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must
be supported by clear and convincing evidence. See, e.g., United States V. Ferranti, 66 F.3d 540,
542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if
there is "a serious risk that the [defendant] will attempt to obstruct justice, or to threaten,
injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(f)(2)(B); see also United
States V. Friedman, 837 F.2d 48 (2d Cir. 1988).
The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the
nature and circumstances of the crimes charged; (2) the weight of the evidence against the person;
(3) the history and characteristics of the defendant, including the person's "character
[and]
financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See
18 U.S.C. $ 3142(g). Evidentiary rules do not apply at detention hearings and the government is
entitled to present evidence by way of proffer, among other means. See 18 U.S.C. $ 3142(f)(2);
see also United States V. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled
to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States V.
Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same).
Where a judicial officer concludes after a hearing that "no condition or combination of
conditions will reasonably assure the appearance of the person as required and the safety of any
other person and the community, such judicial officer shall order the detention of the person before
trial." 18 U.S.C. $ 3142(e)(1). Additionally, where, as here, a defendant is charged with
committing an offense involving a minor victim under 18 U.S.C. $ 1591, it shall be presumed,
subject to rebuttal, that no condition or combination of conditions will reasonably assure the
appearance of the defendant as required and the safety of the community. 18 U.S.C.
$ 3142(e)(3)(E).
II.
Discussion
The defendant should be detained pending trial. For the reasons set forth below, it is
difficult to overstate the risk of flight and danger to the community if the defendant is released,
and for those reasons, the defendant cannot overcome the statutory presumption in favor of
detention in this case.
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=== Page 19 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 5 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 5
A. The Defendant Poses an Extreme Flight Risk
Each of the relevant factors to be considered as to flight risk - the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant -
counsel strongly in favor of detention.
1. The Nature and Circumstances of the Offense and the Strength of the Evidence
The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C.
$ 3142(g)(1) (specifically enumerating "whether the offense. involves a minor
victim"
as
a
factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a
defendant charged with that offense, there is a presumption that no condition or combination of
conditions will reasonably assure the appearance of the defendant as required and the safety of the
community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's
conduct was committed serially, over a period of years, and affected dozens of victims.
The seriousness of the charge is also reflected in the penalties the defendant faces, which
include up to 45 years of incarceration for Counts One and Two of the Indictment. As the Second
Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of
flight. See Jackson, 823 F.2d at 7; see also United States V. Cisneros, 328 F.3d 610, 618 (10th Cir.
2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her
gave her a strong incentive to abscond); United States V. Townsend, 897 F.2d 989, 995 (9th Cir. 1990)
("Facing the much graver penalties possible under the present indictment, the defendants have an even
greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades
in prison. Even in the absence of means-which, as discussed in detail below, the defendant has
in abundance-this fact alone would provide a compelling incentive for anyone to fail to appear.
It is particularly compelling for a defendant who is 66 years old and therefore faces the very real
prospect of spending the rest of his life in prison if convicted.
The likelihood of a substantial period of incarceration is buttressed by the strength of the
evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges
that the defendant sexually abused dozens of minor victims, and the conspiracy count lists
numerous overt acts committed in furtherance of the defendant's crimes.4
3 The current penalties for violations of 18 U.S.C. $ 1591 include a 10 year mandatory minimum
sentence. However, that punishment was created through an amendment to the statute in 2006.
The penalty for a violation of Section 1591 during the period charged in the Indictment, and
therefore relevant here, was a maximum of 40 years' imprisonment.
4 With respect to the evidence in this case, the Court should start its analysis by accepting that the
Indictment is sufficient, on its own, to establish probable cause that the defendant committed the
crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an
evidentiary hearing addressing the existence of probable cause required in every § 3142(e) case in
which an indictment had been filed, the court would spend scarce judicial resources considering
that which a grand jury had already determined, and have less time to focus on the application of
EFTA00015550

=== Page 20 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 6 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 6
Multiple victims, including several specified in the Indictment, have provided information
against the defendant. That information is detailed, credible, and corroborated, in many instances,
by other witnesses and contemporaneous documents, records and other evidence-including, as
further detailed below, evidence from a search of the New York Residence on the night of the
defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude
young women or girls. Such corroborating evidence also includes documents and other materials,
such as contemporaneous notes, messages recovered from the defendant's residence that include
names and contact information for certain victims, and call records that confirm the defendant and
his agents were repeatedly in contact with various victims during the charged period. Put simply,
all of this evidence - the voluminous and credible testimony of individuals who were sexually
abused by the defendant as minors, each of whom are backed up by other evidence - will be
devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention.
Finally, it bears noting that neither the age of the conduct nor the defendant's previous non-
prosecution agreement ("NPA") with a different federal district pose any impediment to his
conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. $ 3283,
which was amended in 2003 to extend the limitations period for conduct that was timely as of the
date of the amendment, to any time during the lifetime of the minor victim. See United States V.
Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute
of limitations for sex offenses involving minors during the time the previous statute was still
running, the extension was permissible); United States V. Pierre-Louis, No. 16 Cr. 541 (CM), 2018
WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same).
Moreover, with respect to the NPA, that agreement, to which the Southern District of New
York was not a party, which by its express language pertained exclusively to the SDFL
investigation, and which did not purport to bind any other Office or District, does not preclude
prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit
that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind
another." United States V. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds
only the office of the United States Attorney for the district in which the plea is entered unless it
affirmatively appears that the agreement contemplates a broader restriction.") (citing United States
V. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the
agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis
similarly extends to a non-prosecution agreement. See United States V. Laskow, 688 F. Supp. 851,
854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement
to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States
Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit,
which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can
affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi,
771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely
the presumptions and the $ 3142(g) factors in deciding whether the defendant should be
detained.").
EFTA00015551

=== Page 21 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 7 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 7
conduct that occurred in New York. The prior NPA included a list of several dozen victims
identified in the prior investigation, all of whom were abused in the State of Florida, and none of
whom are a part of the conduct charged in Count Two of the instant Indictment.
Each of these factors-the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration-creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
2. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. The
defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt
to flee. Indeed, his potential avenues of flight from justice are practically limitless.
As the defendant acknowledged in his most recent New York State sex offender
registration, he has six residences, including two in the U.S. Virgin Islands (including his own
private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and
Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion
alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach
estate is more than $12 million. The defendant's primary residence is a private island in the U.S.
Virgin Islands, a place where any sort of meaningful supervision would be all but impossible.
Moreover, the defendant has access to innumerable means to flee. His sex registration
documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven
Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade,
and a Hummer II. These cars are registered in various states and territories including the Virgin
Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets,
giving him the ability to leave the country secretly and on a moment's notice and to go virtually
anywhere he wants to travel. He is a very frequent international traveler and regularly travels to
and from the United States by private plane. In particular, between January 1, 2018, and the
present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which
Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport
arriving on just such a private international flight after having spent approximately three weeks
abroad. Extensive international travel of this nature further demonstrates a significant risk of
flight. See, e.g., United States V. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be
no assurance that, upon release, the defendant would suddenly lack access to such means of travel.
Finally, the defendant has no meaningful ties that would keep him in this country. The
defendant has no known immediate family. He is not married and has no children. He has friends
and associates worldwide, as demonstrated by his extensive international travel, and his
professional obligations, if any, can and seemingly are plainly capable of being handled by the
defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain
in the country, while he would have every incentive (and every resource needed) to flee.
Nor would home confinement with electronic monitoring reasonably assure the
defendant's presence as required. At best, home confinement with electronic monitoring would
EFTA00015552

=== Page 22 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 8 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 8
merely reduce his head start should he decide to flee. See United States V. Zarger, No. 00 Cr. 773,
2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application
for bail in part because home detention with electronic monitoring "at best
limits
a
fleeing
defendant's head start"); see also United States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744,
at *9 (N.D. Cal. Feb. 2018) (same); United States V. Anderson, 384 F.Supp.2d 32, 41 (D.D.C.
2005) (same); United States V. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y.
Oct. 10, 2002) (same).
Finally, there can be little doubt that the defendant is in a position to abandon millions of
dollars in cash and property securing any potential bond and still live comfortably for the rest of
his life. These resources, and the ease with which the defendant could flee and live outside the
reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to
this District-make the risk of flight exceptionally high in this case, particularly when considered
in conjunction with the strength of the government's case and the lengthy sentence the defendant
could receive if convicted.
B. The Defendant Poses a Risk of Danger to the Community and of Engaging in
Obstruction of Justice
The release of the defendant, under any conditions, would pose a significant threat to the
community and to the ongoing investigation.
As described above, where there is probable cause to believe that an individual has
committed an offense under 18 U.S.C. $ 1591, it is presumed that no condition or combination of
conditions can reasonably assure the safety of the community. 18 U.S.C. $ 3142(e)(3). Here, not
only is the defendant charged with very serious sex crimes against minors, he has already
previously admitted to-and been convicted of-engaging in related conduct. Specifically, in
June 2008, the defendant pled guilty in state court to one count of procuring a person under the
age of 18 for prostitution, a felony, and he currently is a registered sex offender, under
classification level three in New York-defined as presenting a "high" risk of committing another
sex crime and harm to the community. While the conduct presently alleged does not post-date the
2008 conviction, it nevertheless underscores the risk he poses to the community if released.
Additionally, and in connection with the investigation of the defendant's offense in Florida,
there were credible allegations that the defendant engaged in witness tampering, harassment, or
other obstructive behaviors. In fact, according to publicly-filed court documents, there were
discussions between prosecutors and the defendant's then-counsel about the possibility of the
defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with
reference to 18 U.S.C. $ 1512, which criminalizes "[t]ampering with a witness, victim, or
informant." For example, in a communication from the defendant's then-counsel to prosecutors
in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant
had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an
official proceeding" and that the defendant "in particular, changed travel plans and flew with both
[redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to
attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally
EFTA00015553

=== Page 23 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 9 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 9
harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process
all in violation of 18 USC 1512(d)(1)." Doe V. United States, 08 Civ. 80736 (S.D. Fla.), Dkts.
361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. $ 1512(d), prosecutors also proposed
that the defendant could plead guilty to 18 U.S.C. $ 403, that is, a knowing or intentional violation
of the privacy protection of child victims and child witnesses, to which the defendant's then-
counsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed
a possible obstruction plea that "could rely on the incident where Mr. Epstein's private
investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10.
The defendant's apparent previous willingness to obstruct a federal investigation, harass or
tamper with witnesses, and hire private investigators that "forc[ed] off the road" the father of an
individual relevant in the investigation is alarming. It should especially weigh on the Court's
consideration here because the defendant was apparently willing to take those steps before even
being charged and thus facing federal indictment; the incentive to interfere in the Government's
case here, where an Indictment has been returned, is exponentially greater. And as discussed
above, the defendant has nearly limitless means to do so.
Finally, despite having been previously convicted of a sex offense involving an underage
victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking
women or girls in his Manhattan mansion. In a search of the New York Residence on the night of
his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers
discovered not only specific evidence consistent with victim recollections of the inside of the
mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at
least hundreds-and perhaps thousands-of sexually suggestive photographs of fully- or partially-
nude females. While these items were only seized this weekend and are still being reviewed, some
of the nude or partially-nude photographs appear to be of underage girls, including at least one girl
who, according to her counsel, was underage at the time the relevant photographs were taken.
Additionally, some of the photographs referenced herein were discovered in a locked safe, in which
law enforcement officers also found compact discs with hand-written labels including the
following: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pics nude." The defendant, a
registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a
continuing danger to the community and an individual who faces devastating evidence supporting
deeply serious charges.
5 The redactions above are contained in the publicly filed version of the quoted document.
6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator,
N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post
yesterday. 'It's the difference between a murderer and a person who steals a bagel."); Philip
Weiss, The Fantasist, New York Magazine (2007) ("It's the Icarus story, someone who flies too
close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.").
EFTA00015554

=== Page 24 ===
Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 10 of 10
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 10
CONCLUSION
As set forth above, in this case, the risk of flight in this case is extraordinarily real. The
defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious
offenses that carry a potential statutory sentence of up to 45 years' imprisonment-even a fraction
of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In
sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive
international travel and ties outside the country, and his vast wealth, including his access to and
ownership of private planes, all provide the defendant with the motive and means to become a
successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated-the abuse
dozens of underage, vulnerable girls-along with his demonstrated willingness to harass,
intimidate and otherwise tamper with victims and other potential witnesses against him, render his
dangerousness readily apparent.
Accordingly, the Government respectfully submits that the defendant cannot and will not
be able to meet his burden of overcoming the strong presumption in favor of detention, that there
are no conditions of bail that would assure the defendant's presence in court proceedings in this
case or protect the safety of the community, and that any application for bail should be denied.
Very truly yours,
GEOFFREY S. BERMAN
United A States Attorney
By:
/
/
Assistant United States Attorney
Southern District of New York
Tel: (212) 637-2415 / 2225 / 2324
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
Hon. Richard M. Berman, United States District Judge
EFTA00015555

=== Page 25 ===
Case 1:19-cr-00490-RMB Document 11-2 Filed 07/12/19 Page 1 of 2
Date:
M BEACH POLICE DEPARTMENT
Page:
Time:
Incident Report
Program:
Case No
(Continued)
Entered By. :
On
2006, I received several phone calls throughout the day
from
who stated he had been followed aggressively by a private
investigator.
stated that as he drove to and from work and
running errands throughout the county, the same vehicle was behind him
running other vehicles off the road in an attempt not to lose sight of
's vehicle.
I explained to him as Mr. Epstein had retained new legal council it
was possible it would be new private investigators following him to
observe his daily activities. I also explained to him that there was
a meeting scheduled with
and
at
scheduled on
I attempted to call
to inform
of the
private investigators following
however;
I received other phone calls from
and
who
/
advised they were able to acquire the private investigators license
plate information. The subject following them was again driving very
aggressively and caused
to run off the road.
stated
the vehicle is a green Chevy
bearing Florida tag
#
The vehicle is registered to
of
Florida.
is employed with
Investigations from
/
Florida.
is a licensed Private Investigator in the State of Florida.
Since the discovery of the threat made against one of the victims in
this case
/
I requested subpoenas for all calls made to and
received from
during the month of March 2006 for her
cell phone and home phone. I had confirmed with Florida State
the exact dates of Spring Break
The Spring Break
was from March 4, 2006 through March 12, 2006. I received a subpoena
from
with all calls made during the month of
I reviewed the 989 calls made and received during the month of March
2006. I observed on
2006,
made and received thirty
five calls during that day.
Date
Time
Seconds
In/Out
To/From
-06
11:03 AM
492
Outbound
-06 11:16 AM
6
Inbound
06 11:22 AM
887.2
Inbound
-06 11:37 AM
48
Outbound
06 11:39 AM
28.2
Inbound
06 12:02 PM
727.2
Inbound
The table reflects the date of the calls, time of day (EST), duration
EFTA00015556

=== Page 26 ===
Case 1:19-cr-00490-RMB Document 11-2 Filed 07/12/19 Page 2 of 2
Date:
LM BEACH POLICE DEPARTMENT
Page:
Time:
Incident Report
Program:
Case No
:
(Continued)
of call in seconds, inbound or outbound calls and calls made to or
from
phone. On
,
2006, at 11:03 am,
made a call
to the victim which lasted 492 seconds (8 minutes and 2 seconds)
The victim then returned the call at 11:16 am which lasted 6 seconds.
The victim then made contact with
at 11:22 am for 877.2 seconds
(14 minutes and 6 seconds). These sequences of calls were consistent
with what the victim had described to me on the date of the
intimidation. Immediately after speaking with the victim,
makes
a call to
Epstein's assistant, which lasts for
forty-eight seconds. A call is then immediately received, a telephone
number registered to a Corporation affiliated with Jeffrey Epstein
located at 457 Madison Ave in New York. An extensive computer check
revealed 457 Madison Ave is a business address in which Epstein has
his corporations assigned to. Epstein had corporation attorney,
register the businesses and register himself as an
agent. I also observed Epstein has his El Zorro Ranch Corporation,
New York Strategy Group, Ghislaine Corporation, J Epstein and Company
and the Financial Strategy Group registered to this same address.
Finally, a third call is received by
at 12:02 pm from the same
corporate number which lasts 12 minutes and 1 second. It should be
noted that there is no further contact with either the victim during
the month of
of 2006. I also noted that there was no
further contact with
or Jeffrey Epstein during the
remainder of the month of
2006.
On
, 2006,
telephoned me to inform me of the
meeting that occurred with Atty.
and
reference
this case.
Inv Continues.
EFTA00015557

=== Page 27 ===
Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 1 of 2
ate: 7/19/06
PALM BEACH POLICE DEPARTMENT
Page:
82
ime: 15:01:37
Incident Report
Program: CMS301L
NARRATIVE # 42
Reported By: RECAREY, JOSEPH
4/14/06
Entered By.: ALTOMARO, NICKIE A.
4/18/06
The Grand Jury Subpoenas were personally served to the individuals
they were issued to. On April 5, 2006, at approximately 7:30 p.m., I
personally served the parents of who had informed me that the
private investigators were still photographing the family. On April
EFTA00015558

=== Page 28 ===
Case 1:19-cr-00490-RMB Document 11-3 Filed 07/12/19 Page 2 of 2
ate: 7/19/06
PALM BEACH POLICE DEPARTMENT
Page:
83
ime: 15:01:37
Incident Report
Program: CMS301L
ise No. ... : 1-05-000368
(Continued)
10, 2006, at approximately 2:30 p.m., I served
at her residence in
The subpoena was given to her mother,
I learned through one of the victims that she was personally
contacted through a source that has maintained contact with Epstein.
The source assured she would receive monetary compensation for her
assistance in not cooperating with law enforcement.
also stated
she was told, "Those who help him will be compensated and those who
hurt him will be dealt with." I told
that tampering with a
witness/victim is an arrestable offense and very serious. I asked her
who approached her during this encounter. originally was reluctant
to provide the name of the person who approached her to offer her not
to testify because she felt they were still friends.
On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida
and met with the victim
identified
W/F,
as the person who approached her in Royal Palm Beach while
she was home during Spring Break in March 2006.
also stated she
did not want to pursue the intimidation charges on
was
concerned that the defense attorney was given a copy of the report as
certain things she had told me in confidence were repeated to her by
EFTA00015559


c1: EFTA00017085
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017085.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 5, 2020
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal
Procedure ("Fed. R. Crim. P."), and seeks reciprocal discovery.¹
Disclosure by the Government
Based on your request for discovery in this case, enclosed please find copies of the
materials listed in the attached index, which materials are stamped with control numbers
SDNY_GM_00000001 through SDNY_GM_00012841. If you wish to inspect any of the physical
evidence referenced in these materials, including items listed on search inventories, please let us
know, and we will make arrangements for you to do so.
The Government recognizes its obligations under Brady V. Maryland, 373 U.S. 83 (1963),
and its progeny. Pursuant to those obligations, we are disclosing the information below. This
disclosure should not be taken to indicate that the Government believes the enclosed information
constitutes Brady material. Rather, we make this disclosure in an abundance of caution.
Specifically, the Government discloses the following:
The Government will provide material under Giglio V. United States, 405 U.S. 150, 154
(1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by
the Court.
1
In addition to information provided herein, please note that this Office periodically posts content
on social media platforms including Twitter, Facebook and YouTube. Members of the public may
post comments in response to the Office's postings. We do not control these user-generated
comments, nor do we monitor or regularly review such comments. You may directly access these
social media platforms in the event you believe someone may have posted information relevant to
this case.
06.20.2018
EFTA00017085

=== Page 2 ===
Page 2
Disclosure by the Defendant
In light of your request for discovery in this case, the Government hereby requests
reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow
inspection and copying of: (1) any books, or copies or portions thereof, which are in the
defendant's possession, custody or control, and which the defendant intends to introduce as
evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental
examinations and of scientific tests or experiments made in connection with this case, or copies
thereof, which are in the defendant's possession or control, and which the defendant intends to
introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the
defendant intends to call at trial.
The Government also requests that the defendant disclose prior statements of witnesses he
will call to testify. See Fed. R. Crim. P. 26.2; United States V. Nobles, 422 U.S. 225 (1975). We
request that such material be provided on the same basis upon which we agree to supply the
defendant with 3500 material relating to Government witnesses.
Sentence Reduction for Acceptance of Responsibility
This Office will oppose the additional one-point reduction under the Sentencing Guidelines
available for defendants who plead prior to the Government's initiation of trial preparations
pursuant to U.S.S.G. $ 3E1.1(b), in the event your client has not entered a plea of guilty six weeks
prior to trial. We will follow this policy whether or not suppression or other pretrial motions
remain outstanding after this date and even if the trial date has not been announced by the Court
six weeks in advance of the trial.
Finally, please be advised that pursuant to the policy of the Office concerning plea offers,
no plea offer is effective unless and until made in writing and signed by authorized representatives
of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not
reduced to writing and signed by authorized representatives of the Office cannot and do not
constitute a "formal offer" or a "plea offer," as those terms are used in Lafler V. Cooper, 132 S.Ct.
1376 (2012); Missouri V. Frye, 132 S.Ct. 1399 (2012).
Confidential Non-PDF
Confidential
Bates Start
Bates End
Summary Description
Files
Documents
Ghislaine Maxwell Joint Automated
SDNY_GM_00000001
SDNY_GM_00000002
Booking System Summary
Pen Register Orders and
SDNY_GM_00000003
SDNY_GM_00000044
Applications
SDNY_GM_00000045
SDNY_GM_00000717
Search Warrants and Applications
Confidential
Immigration and Travel Records for
Jeffrey Epstein and Ghislaine
SDNY_GM_00000718
SDNY_GM_00000833
Maxwell
Unsealing materials pertaining to 15
SDNY_GM_00000834
SDNY_GM_00000905
Civ 7433 (RWS), 19 Misc 149 (CM)
06.20.2018
EFTA00017086

=== Page 3 ===
Page 3
Unsealing materials pertaining to 17
SDNY_GM_00000906
SDNY_GM_00000962
Civ 0616 (SN), 19 Misc 179 (SN)
Airline Reporting Corporation
records for Ghislaine Maxwell,
SDNY_GM_00000963
SDNY_GM_00000964
SDNY_GM_00000963
Confidential
Alaska Airlines records for Ghislaine
Maxwell,
and
SDNY_GM_00000965
SDNY_GM_00000965
Confidential
SDNY_GM_00000967;
SDNY_GM_00000969;
SDNY_GM_00000971;
SDNY_GM_00000973;
SDNY_GM_00000974;
Amazon Records for Jeffrey Epstein
SDNY_GM_00000966
SDNY_GM_00000976
SDNY_GM_00000976
and Ghislaine Maxwell
Confidential
American Airlines records for
Ghislaine Maxwell,
SDNY_GM_00000977
SDNY_GM_00001012
and
Confidential
SDNY_GM_00001013
SDNY_GM_00001014
SDNY_GM_00001014
Apple Records for Jeffrey Epstein
Confidential
SDNY_GM_00001015
SDNY_GM_00003637
AT&T Records
Confidential
Bank of America Records relating to
SDNY_GM_00003638
SDNY_GM_00003701
Confidential
Century Link Records for the
SDNY_GM_00003702
SDNY_GM_00003702
number
Confidential
Citibank Records relating to
SDNY_GM_00003703
SDNY_GM_00004639
SDNY_GM_00004511
and Ghislaine Maxwell
Confidential
Delaware Division of Corporations
SDNY_GM_00004640
SDNY_GM_00004649
Records relating to LSJ LLC
Delta Airlines Records for Ghislaine
Maxwell,
SDNY_GM_00004650
SDNY_GM_00004655
Confidential
SDNY_GM_00004656
SDNY_GM_00004656
Confidential
Expedia Records relating to
SDNY_GM_00004657
SDNY_GM_00004657
Ghislaine Maxwell
Experian Records relating to
Ghislaine Maxwell,
and
SDNY_GM_00004658
SDNY_GM_00004721
Confidential
Gold Coast Federal Credit Union
SDNY_GM_00004722
SDNY_GM_00004762
records relating to
Confidential
Google records regarding account
information for Jeffrey Epstien and
SDNY_GM_00004763
SDNY_GM_00004776
Ghislaine Maxwell
Confidential
Instagram records for Ghislaine
SDNY_GM_00004776
SDNY_GM_00004781
Maxwell
SDNY_GM_00004782
SDNY_GM_00005414
Interlochen Records
Confidential
SDNY_GM_00005415
SDNY_GM_00005416
MCC Request for Emails
06.20.2018
EFTA00017087

=== Page 4 ===
Page 4
Microsoft Records regarding
account information for Jeffrey
SDNY_GM_00005417
SDNY_GM_00005417
Epstein
SDNY_GM_00005431;
SDNY_GM_00005432;
MoneyGram Records relating to
SDNY_GM_00005433;
Ghislaine Maxwell,
SDNY_GM_0005418
SDNY_GM_00005444
SDNY_GM_00005435
and
Confidential
New York State Department of State
SDNY_GM_00005445
SDNY_GM_00005484
records
SDNY_GM_00005487;
SDNY_GM_00005488;
SDNY_GM_00005490;
Oath Holdings records for Jeffrey
SDNY_GM_00005485
SDNY_GM_00005491
SDNY_GM_00005491
Epstein email accounts
Confidential
Professional Children's School
SDNY_GM_00005492
SDNY_GM_00005531
Records
Confidential
Flight manifests and records from
SDNY_GM_00005532
SDNY_GM_00005676
1991 - 2013
Confidential
SDNY_GM_00006007;
SDNY_GM_00006008;
SDNY_GM_00006009
;
SDNY_GM_00005677
SDNY_GM_00006060
SDNY_GM_00006010
Charles Schwab Records
Confidential
SDNY_GM_00006061
SDNY_GM_00006079
Shoppers Travel Records
Confidential
SDNY_GM_00006080
SDNY_GM_00006096
Southwest Records
Confidential
SDNY_GM_00006097
SDNY_GM_00006129
Capital One Records
Confidential
SDNY_GM_00006130
SDNY_GM_00007425
TD Bank Records
Confidential
SDNY_GM_00007521
--
SDNY_GM_00007580;
SDNY_GM_00007620
PayPal Records for accounts in the
--
name of Jeffrey Epstein,
SDNY_GM_00007426
SDNY_GM_00007641
SDNY_GM_00007641
and Ghislaine Maxwell
Confidential
SDNY_GM_00007642
SDNY_GM_00007654
--
SDNY_GM_00007658;
SDNY_GM_00007666;
SDNY_GM_00007676;
SDNY_GM_00007642
SDNY_GM_00007677
SDNY_GM_00007677
T-Mobile records
Confidential
Materials from
and
(Epstein Estate
SDNY_GM_00007678
SDNY_GM_00008136
Executors)
Confidential
SDNY_GM_00008137
SDNY_GM_00008137
UMB Bank no records notification
Confidential
United Airlines records for Ghislaine
Maxwell,
SDNY_GM_00008138
SDNY_GM_00008146
Confidential
06.20.2018
EFTA00017088

=== Page 5 ===
Page 5
UBS Bank records for accounts in
SDNY_GM_00009087;
the name of or related to Ghislaine
SDNY_GM_00008147
SDNY_GM_00010164
SDNY_GM_00009088
Maxwell
Confidential
USAA records for accounts in the
name of or related to Ghislaine
SDNY_GM_00010165
SDNY_GM_00010355
Maxwell
US Virgin Islands Division of
Corporations records for Laurel Inc,
SDNY_GM_00010356
SDNY_GM_00010456
Maple Inc, and Nautilus, Inc
Confidential
Venmo records name of Jeffrey
Epstein,
and
SDNY_GM_00010457
SDNY_GM_00010459
Ghislaine Maxwell
Confidential
SDNY_GM_00010460
SDNY_GM_00010461
Verizon records
Confidential
Flight manifest records from
SDNY_GM_00010462
SDNY_GM_00011483
Confidential
SDNY_GM_00011484
SDNY_GM_00011488
Western Union no accounts found
Confidential
SDNY_GM_00011489;
SDNY_GM_00011490;
SDNY_GM_00012217;
SDNY_GM_00012220;
SDNY_GM_00012305;
SDNY_GM_00012359;
SDNY_GM_00012382;
SDNY_GM_00012396
TD Ameritrade Materials for
SDNY_GM_00012405
account in the name of Jeffrey
SDNY_GM_00011489
SDNY_GM_00012474
SDNY_GM_00012435
Epstein
Confidential
SDNY_GM_00012475
SDNY_GM_00012841
Materials from Granite Reality
Confidential
Very truly yours,
Acting United States Attorney
b
Enclosure
06.20.2018
EFTA00017089


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 21:29:01 +0000
Inline-Images: image001.png
Thanks so much
Miss you and hope all is well with you ©
From:
Sent: Thursday, July 2, 2020 1:26 PM
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats on this
Great job!
Hope you and your family are doing well!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO STATES UNITED STATES
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
OF
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
EFTA00017722

=== Page 2 ===
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
EFTA00017723

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
EFTA00017724

=== Page 4 ===
unless and until proven guilty.
EFTA00017725


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=== Page 1 ===
From:
To:
Cc:
Subject: Draft SW
Date: Wed, 01 Jul 2020 23:49:13 +0000
Attachments: New_Hampshire_Premises_SW_Affidavit.docx
Attached
EFTA00016162


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about
Epstein
Date: Mon, 24 Aug 2020 16:24:18 +0000
Attachments: 07_04_2020_Letter_From_Prisoner_Mentioned_By_Anthony_Lombardino.pdf
Forwarding per our usual practice.
Thanks,
From:
Sent: Monday, August 24, 2020 11:55 AM
To:
Cc:
Subject: RE: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about Epstein
Sorry, this goes with that last one.
From:
Sent: Monday, August 24, 2020 11:49 AM
To:
Cc:
Subject: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about Epstein
Attached is a Civilian Crime Report for you to review. We sent our usual letter with the
form to be completed, but this particular submission does not really fit that so we might
not get anything more, but let us know if we do that you want to see it.
, please
make a note in the log. Thank you.
EFTA00016971


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=== Page 1 ===
From:
(USANYS)"
To: "Strauss, Audrey (USANYS)"
Cc:
(USANYS)"
Subject: Re: Epstein FOIA Update
Date: Sat, 10 Apr 2021 00:17:48 +0000
I'll have the briefing pulled and will send to you.
Sent from my iPhone
> On Apr 9, 2021, at 8:06 PM, Strauss, Audrey (USANYS)
wrote:
V
> I will have to do catching up here. If there are materials I can review over the weekend, please send.
> Thanks.
>
> Sent from my iPhone
>
>> On Apr 9, 2021, at 7:28 PM,
(USANYS)
wrote:
>> Main Justice on the FOIA response here (specifically whether more documents might be produced on
reconsideration). In particular, the Court perceived a possibility
EFTA00015360


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=== Page 1 ===
From:
(USANYS)"
To:
Subject: Accepted: Meet re: Epstein
Date: Fri, 28 Jun 2019 17:41:11 +0000
Importance: Normal
Attachments: unnamed
EFTA00014520


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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
-
Date: Mon, 12 Aug 2019 12:08:41 +0000
Attachments:
wav
Time: Aug 12, 2019 8:08:41 AM
Click attachment to listen to Voice Message
EFTA00015701


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: passport
Date: Tue, 16 Jul 2019 21:23:02 +0000
Importance: Normal
Please do file. And please circulate their filing.
From:
Sent: Tuesday, July 16, 2019 5:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: passport
Filing our letter now. Here's their passport explanation, from the defense filing:
Eighth, as for the Austrian passport the government trumpets, it expired 32 years
ago. And the government offers nothing to suggest - and certainly no evidence -
that Epstein ever used it. In any case, Epstein - an affluent member of the Jewish
faith - acquired the passport in the 1980s, when hijackings were prevalent, in
connection to Middle East travel. The passport was for personal protection in the
event of travel to dangerous areas, only to be presented to potential kidnapers,
hijackers or terrorists should violent episodes occur.
Assistant United States Attorney
Southern District of New York
EFTA00014478


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell
Date: Sun, 28 Nov 2021 20:36:26 +0000
Yes, I will talk to the team!
Special Assistant to the U.S. Attorney
Southern District of New York
From:
Sent: Sunday, November 28, 2021 3:31 PM
To:
Subject: Fwd: United States V. Ghislaine Maxwell --
Hey
Can someone please reserve a seat for me? l'll try to get there at 9 after I drop off the kids.
Begin forwarded message:
From:
Date: November 28, 2021 at 9:59:11 AM EST
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>, USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>, USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
EFTA00015659

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
(212) 637-2225
EFTA00015660


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=== Page 1 ===
From:
"
)"
To:
(TROOPERS)"
Cc:
)"
,
)"
Subject: Expedia subpoena
Date: Fri, 24 Jan 2020 17:07:37 +0000
Attachments: 2020-01-24,_subpoena_to_Expedia.pdf
One more subpoena to serve relating to Maxwell travel, please.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016829


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
)"
)"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: Epstein PR Final review
Date: Mon, 08 Jul 2019 14:25:07 +0000
Importance: Normal
Yep, confirmed. Thanks all!!
From:
(USANYS)
Sent: Monday, July 8, 2019 10:24 AM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
)
>;
>;
Cc:
(USANYS) [Contractor]
>;
(USANYS)
Subject: RE: Epstein PR Final review
Good with me. I believe we are using FBI line but you should confirm that with
From:
(USANYS)
Sent: Monday, July 08, 2019 10:17 AM
To:
(USANYS)
>;
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
is
is
is
)
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Any other edits? Or are we good to finalize the release?
From:
(USANYS)
Sent: Monday, July 8, 2019 9:55 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
>;
(USANYS)
is
is
>;
)
EFTA00014645

=== Page 2 ===
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Also in
quote: Are we trying to say no matter where the incident took place?
FBI Assistant Director
said: "We are asking anyone who may have been victimized
by Jeffery Epstein, or anyone who may have information about his alleged criminal behavior, to please call us.
The number is 1-800-CALL-FBI. We want to hear from you, regardless of the age you are now, or whatever age
you were then, no matter the incident that took place. The bravery it takes to call us might empower others to
speak out about the crimes committed against them. It is important to remember there was never, nor will
there ever be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come first."
From:
(USANYS)
Sent: Monday, July 8, 2019 9:39 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
>;
(USANYS)
is
(USANYS)
in
is
^
>;
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: Epstein PR Final review
Importance: High
Attached is the final PR for review. Please note that
quote includes the number to call, so we need to
finalize that as soon as possible. Thanks.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Bec:
Subject: RE: FW: Ghislaine Maxwell 02879-509
Date: Tue, 17 Nov 2020 11:44:37 +0000
Embedded: RE:_FW:_Ghislaine_Maxwell_02879-509.msg
Sender:
Subject: RE: FW: Ghislaine Maxwell 02879-509
Message-Id: <5FB3B79A020000DE000DC5DB@SMTP1.BOP.GOV>
Recipient:
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=== Page 1 ===
U.S. Department of Justice
Office of the Inspector General
MEMORANDUM OF INVESTIGATION
Case Number:
Reporting Office:
2019-010614
New York Field Office
On August 14, 2019, at the United States Attorney's Office for the Southern District of New York
(SDNY), an interview was conducted with Federal Bureau of Prisons (BOP) Metropolitan Correction
Center (MCC) Lieutenant
Present for this interview were Assistant United States
Attorney (AUSA)
AUSA
Federal Bureau of Investigation (FBI)
Special Agent (SA)
New York City Police Detective, assigned as a Task Force Officer
(TFO) to the FBI, and
SA for the Department of Justice (DOJ) Office of the Inspector
General (OIG).
I
Prior to the start of the interview in front of all mentioned above, SA
verbally explained to
Lieutenant
her involvement in the interview was voluntary and it was related to the
actions at the MCC the night of August 9, 2019 and the morning of August 10, 2019, specifically
involving MCC inmate Jeffrey Epstein. Lieutenant
stated that she understood that this
was a criminal investigation and that her involvement was voluntary.
After the verbal explanation that this was a voluntary interview, SA
mistakenly provided
Lieutenant
DOJ OIG Form III-226/3 (04/23/07) Warnings and Assurances to
Employee Required to Provide Information. Lieutenant
read and signed that without
question. SA
intended to give Lieutenant
DOJ OIG Form III-226/2
(04/23/07) Non-Custodial/Employee. SA Carpenter intended to provide
ith DOJ OIG
Form OIG Form III-226/2, Warnings and Assurances to Employee Requested to Provide Information on
a Voluntary Basis.
It is the belief to all present in the room that
knew her interview and answers were
voluntary and not compelled.
Prepared By:
Preparer Title:
Reviewed By:
Reviewer Title:
Special Agent
Acting ASAC
Signature:
Signature:
Digitally signed by
Digitally signed by
Date: 2019.12.08 08:17:50
Date: 2019.12.12 09:22:58
-05'00'
OIG Form III-210/4 (09/06/2018) This document contains neither recommendations nor conclusions of the IG. It is the property of the IG and is loaned to
your agency; it and its contents are not to be distributed outside of your agency.
EFTA00016903


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=== Page 1 ===
From:
To:
Cc:
Bec:
Subject: Re: SK
Date: Thu, 01 Oct 2020 19:29:05 +0000
Embedded: Re:_SK.msg
Sender:
Subject: Re: SK
Message-Id:
To:
Cc:
EFTA00014583


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=== Page 1 ===
From:
To:
Cc:
Subject: Corrected SW
Date: Thu, 02 Jul 2020 11:45:21 +0000
Attachments: SDNY_Premises_Search_Warrant_Bundle_(second_revised)pdf
Attached is the corrected SW binder, which FBI informs me they are comfortable with. The only difference from the last
binder I sent you is to change the date and time that the cell site simulator revealed that the phone is located at the
subject premises from last night at 10:15pm to this morning at 7:36am. This should be ready to swear out as soon as the
Judge is available.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00014920


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: U.S. V. Maxwell, S2 20 Cr. 330 (AJN) - Letter re Proposed Limiting Instructions
Date: Mon, 22 Nov 2021 14:03:54 +0000
Attachments: 2021.11.22_Letter_to_Judge_Nathan_re_Limiting_Instructions.PDF
Inline-Images: image001.gif; image002.jpg
The defense wants to respond to our letter on the jury instructions later.
From:
Sent: Monday, November 22, 2021 12:42 AM
To:
Cc:
Subject: [EXTERNAL] U.S. V. Maxwell, S2 20 Cr. 330 (AJN) - Letter re Proposed Limiting Instructions
Dear Chambers -
With apologies for the delay, attached please find the defendant's letter regarding the proposed limiting instructions in
the Court's Opinion and Order, dated November 19, 2021. The defense submits this letter temporarily under seal.
Regards,
COHEN & GRESSER LLP
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00014694


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: New mcc problems
Date: Fri, 17 Jan 2020 16:27:31 +0000
Bruce,
Thanks for raising these issues with us in advance of the conference. We appreciate the opportunity to try and
address them with MCC in advance. Below are responses based on our conversation with
, and
we have copied all counsel because until Judge Karas instructs us otherwise, we intend to communicate with all
counsel of record.
1 -
has advised us that allowing a tour of this kind is a security risk for the institution because, among
other things, you have asked to tour areas where many inmates will be, and the institution cannot be locked down
for purposes of an outside person taking a tour absent a very specific and pressing reason.
also advised
that were the Court to order such a tour, MCC would set very specific conditions and ask that the Government
also be present.
2-
has advised that she is working with SIS to get a date and time for the inspection of physical
evidence, and hopefully will be reaching out today to schedule the inspection.
3 -
has advised that upon receiving your email, she had her staff speak with
about the
heat. The staff took heat reports in the unit and found the temperature was high. The staff made adjustments and
there have not been complaints since. We have asked for another temperature reading to be taken in the unit
before Wednesday's conference to ensure the temperature is at an acceptable level.
4-
has advised that she asked you for additional information that she can discuss with the Warden in
order to assess the request for a family visit, but has not heard back from you. As previously discussed, in order
for the MCC to make an exception for your client, a social visit must be necessary for preparation of the defense.
The Government is not trying to, nor does it want to be, in the middle of that assessment, but we understand
from the MCC that your most recent request was conclusory and they need more detail to make an assessment of
this new request.
Co-Chief, Narcotics Unit
Original Message
From: Bruce Barket
Sent: Thursday, January 16, 2020 11:43 AM
To:
Cc: Aida Leisenring
Subject: New mcc problems
In case we don't have enough to do on the 22nd, I intend to raise several issues about the jail. In no particular
order;
EFTA00017026

=== Page 2 ===
1. They are refusing to allow us to view the cells and common areas where Nick has been held for nearly 3 years.
Initially, we were told we would be permitted and that photographs would be taken and reviewed by the staff. We
are going to file a motion to compel before the 22nd.
2. I have written multiple emails to
asking for an opportunity to view the physical evidence for the July
23rd suicide attempt. She has thus not responded at all
3. We wrote complaining about multiple reports of extreme heat on the tier. One or two inmates had to be
hospitalized. We have not been given an update.
4. We asked for a family visit after next week's court appearance and gave the same reasons we have been
giving. This time we were asked for more detail. I sense a change in the mcc approach. My inclination is to ask
the judge to help here.
I was hoping the new administration would improve the conditions while maintaining
responsiveness.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
EFTA00017027


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=== Page 1 ===
WILMERHALE
November 23, 2021
FOIA CONFIDENTIAL TREATMENT REQUESTED
PURSUANT TO 28 C.F.R. $ 16.8 AND 5 U.S.C. $ 552
(t)
+1 212 230 8888 (f)
By E-mail And By FTP
Assistant United States Attorney
One St. Andrew's Plaza
New York, New York 10007
Re: August 11, 2019 Grand Jury Subpoenas to JPMorgan Chase Bank, N.A., Chase
Bank USA, N.A., and J.P. Morgan Securities LLC; August 16, 2019 and September
3, 2019 Grand Jury Subpoenas to JP Morgan Chase; October 9, 2019 Grand Jury
Subpoenas to JPMorgan Chase Bank, N.A. And All Affiliates
Dear
:
In response to the above-referenced subpoenas and to your request by email on
November 22, 2021, on behalf of our client JPMorgan Chase ("JPMorgan" or the "Firm"), we
submit the enclosed encrypted zip file containing account documentation bates labeled JPM-
SDNY-00065519 through JPM-SDNY-00065530.
As discussed on November 22, 2021, this production includes account documentation
related to account numbe
in the name of ASW Holdings, Inc.
We also wanted to provide the following additional information about the documents in
our November 22, 2021 production. The November 22, 2021 production included account
documentation related to account number
in the name of Financial Trust
Company, Inc. (JPM-SDNY-00065487 through JPM-SDNY-00065493); account documentation
related to account number
in the name of Jeffrey Epstein (JPM-SDNY-00065494
through JPM-SDNY-00065499); and account documentation related to account number
in the name of Ghislaine Maxwell (JPM-SDNY-00065500 through JPM-SDNY-
00065518).
Should you require any additional materials, please do not hesitate to contact us.
***
Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, 28 C.F.R. $ 16.8,
and any other applicable law, rule, or regulation, Wilmer Cutler Pickering Hale and Dorr LLP
requests on behalf of JPMorgan that confidential treatment be accorded to this letter (Bates
numbered JPM-SDNY-CL-012-0001 through JPM-SDNY-CL-012-0003) and the referenced
materials (Bates numbered JPM-SDNY-00065519 through JPM-SDNY-00065530 on JPM-
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-CL-012-0001
EFTA00014878

=== Page 2 ===
WILMERHALE
November 23, 2021
Page 2
SDNY-VOL-012) (collectively, the "Confidential Material"). Accordingly, the Confidential
Material has been marked "Confidential Treatment Requested by JPMorgan Chase." The
Confidential Material contains confidential business information concerning JPMorgan.
Furthermore, public disclosure of the Confidential Material could reasonably be expected to
cause substantial competitive harm to JPMorgan. Accordingly, the Confidential Material is
subject to, without limitation, Exemption 4 of the FOIA, 5 U.S.C. $ 552(b)(4), and the Trade
Secrets Act, 18 U.S.C. $ 1905, and will continue to remain exempt from mandatory disclosure
even after the conclusion of the Department of Justice's ("Department") consideration of this
matter.
We note further that, since the Confidential Material constitutes investigatory records
obtained by the Department in connection with a potential law enforcement proceeding, such
records are subject, at least at present, to the exemption from mandatory disclosure under
Exemption 7(A) of the FOIA, 5 U.S.C. $ 552(b)(7)(A).¹ Since the documents pertain to the
activities of JPMorgan, its employees, and its clients and their employees and agents, and not to
the activities of any federal agency, JPMorgan also believes the documents are exempt from
disclosure pursuant to Exemption 7(C) of the FOIA, 5 U.S.C. $ 552(b)(7)(C).²
Should any third person request the opportunity to inspect or copy the Confidential
Material pursuant to the FOIA or otherwise, we request on behalf of JPMorgan that the
undersigned immediately be notified of such request and be furnished with a copy of all written
materials pertaining to such request (including but not limited to the request and any agency
determination with respect to such request). JPMorgan expects that it will be given an
opportunity to object to such disclosure. And, should the Department be inclined to grant any
such request, it is JPMorgan's expectation that, pursuant to the procedures required by 28 C.F.R.
§ 16.8, and Exec. Order 12,600, 52 Fed. Reg. 23,781 (1987), we will be given reasonable
advance notice of any such decision to enable our client to pursue any remedy that may be
available to it.³ In such event, we request that you telephone the undersigned rather than rely
upon the United States mail for such notice. If the Department is not satisfied that the
submission is exempt from disclosure pursuant to the FOIA, we stand ready to supply further
particulars.
The requests set forth in the preceding paragraphs also apply to any memoranda, notes,
recordings, or other writings of any sort whatsoever which are made by, or at the request of, any
employee of the Department (or any other government agency) and which (1) incorporate,
include, or relate to any of the information contained in the Confidential Material; or (2) refer to
any conference, meeting, telephone conversation, or interview between (a) our client's current or
former employees, associates, representatives, agents, auditors, or counsel and (b) employees of
the Department (or any other government agency).
1
See, e.g., NLRB V. Robbins Tire & Rubber Co., 437 U.S. 214 (1978).
2
See Dep't of Justice V. Reports Comm. For Freedom of Press, 489 U.S. 749 (1989).
3
See, e.g., Chrysler Corp. V. Brown, 441 U.S. 281 (1979).
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-CL-012-0002
EFTA00014879

=== Page 3 ===
WILMERHALE
November 23, 2021
Page 3
This letter is not intended to, and does not, waive any applicable privilege or other legal
basis under which information may not be subject to production.
***
If you have any questions, do not hesitate to contact me at the above-referenced number.
Sincerely,
Enclosure
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-CL-012-0003
EFTA00014880


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject:
Date: Tue, 16 Jul 2019 19:03:13 +0000
Importance: Normal
Apropos of our conversation a few hours ago, I just got a call from
and
who have been retained
to represent
one of the former DOJ folks mentioned on the record yesterday by defense counsel as
having been involved in reviewing the Epstein NPA. She is quite upset about the press coverage and is considering making
a public statement. Would be interested in your thoughts if you have a few minutes to discuss.
EFTA00014476


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
Cc:
(NY) (FBI)"
)"
Subject: Maxwell - CapitalOne/SAKS Credit Card
Date: Mon, 22 Jun 2020 13:14:55 +0000
Attachments: Experian_8-28-19_Prod_ - G_Maxwell.pdf
,
Per the Maxwell's Experian report (August 2019), Maxwell has an open CapitalOne/SAKS credit card (account
number
). Per the Experian report, as of the 8/15/19 the card had a zero balance and the last payment
made on the card was in May of 2019. I have attached the Experian report for your reference.
I am preparing a summary of Maxwell's credit cards. I anticipate sending out that summary either today or
tomorrow.
Best
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00016323


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=== Page 1 ===
From:
)"
To: Brian Burns
, Patrick Smith
Cc:
(USANYS)"
)"
)"
Subject: FW: 20cr330, US V. Maxwell
Date: Wed, 24 Nov 2021 19:42:56 +0000
Attachments: 20cr330_Order_re_Protective_Order_11.24.21.pdf;
20cr330_Subpoena_Protective_Order_11.24.21.pdf
Hi Brian and Patrick,
What is the most efficient way for us to receive a copy of the materials? Would you be able to upload them to our file
sharing platform, or should we coordinate regarding a thumb drive?
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
From: Nathan NYSD Chambers
Sent: Wednesday, November 24, 2021 2:36 PM
To: Brian Burns
>; Patrick Smith
is
)
i
is
is
is
(USANYS)
is
; Jeff Pagliuca
>; Laura Menninger
is
Subject: 20cr330, US V. Maxwell
Counsel:
Attached please find two Orders issued by Judge Nathan, which will be docketed shortly.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00016484


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=== Page 1 ===
From:
(USANYS)"
To:
)
1"
Cc:
,
(USANYS) 3"
Subject: Re:
Date: Sat, 10 Aug 2019 14:05:51 +0000
I mean
Don't understand how this happened.
Sent from my iPhone
> On Aug 10, 2019, at 9:56 AM,
) 1
wrote:
>
>
Part A: Glad to hear you're home!
V
>
Incongruous Part B: MCC, WTF?
>
>
Sent from my iPhone
>
On Aug 10, 2019, at 9:49 AM,
(USANYS)
wrote:
,
For sure.
His victims deserve some sort of modicum of justice and this is not how it should have gone down.
Sent from my iPhone
On Aug 10, 2019, at 9:43 AM,
,
(USANYS) 3
wrote:
It's good to start thinking about. I think if we can do it we certainly should - we would in any other
circumstance where our defendant died, including suicide. It's just slightly more awkward where he was
somehow allowed to commit suicide on a second try in two weeks by a branch of our government. Not a great
year for BOP in the New York area.
Sent from my iPhone
On Aug 10, 2019, at 9:39 AM,
,
(USANYS)
wrote:
Well no of course. I was just curious.
Sent from my iPhone
On Aug 10, 2019, at 9:33 AM,
(USANYS) 3
wrote:
Glad it went on at least.
We can bring a civil forfeiture against the properties IF we're within statute, which we may not be. We'll
have to look at it, but we've got some time, since I'm pretty sure no one's going to want to have that be was our
immediate reaction to his suicide. We can't pursue any kind of general money judgment against the estate - there
we're out of luck.
Sent from my iPhone
EFTA00015657

=== Page 2 ===
On Aug 10, 2019, at 9:27 AM,
(USANYS)
wrote:
Had my surgery. Went so so. Just got home. Will know more in about a week.
In separate news and not to be crass but Epstein! Wow. Can we still pursue forfeiture against the estate?
I believe he has a living brother.
Sent from my iPhone
EFTA00015658


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=== Page 1 ===
Contact: Gloria Allred
Phone:
Email:
Statement of Jane Doe
I was a model in another country when I came to the United States. I was
told by a booker that I needed to meet with a man named Jeffrey Epstein who
was the owner of Victoria's Secret. The booker told me that Mr. Epstein could
help me get into the Victoria's Secret world. It was my childhood dream to be a
Victoria's Secret model. So I went one day in the afternoon and met Mr. Epstein
in his office in his mansion in New York.
A woman introduced herself and suggested to me that I should be
extremely nice to Mr. Epstein, because if he liked me, he would probably have
photographers shooting photos of me right away. The woman told me to go
upstairs and directed me to Jeffrey Epstein's office. Mr. Epstein had a white robe
on and we chatted very briefly. I had my portfolio of photos, but he didn't even
take a look at it. Suddenly, he took his robe off and got close to me. I got up to
leave, but the door was locked. I didn't know what was going on. It was my first
official meeting to be cast in the United States. I was a young girl and confused.
He got very close to me and I had a skirt on. He started to
1 I Page
EFTA00017102

=== Page 2 ===
At that point I ran to the door again and figured out
how to get out of there. A girl outside asked me where I was going and she said
to be careful. She said that Mr. Epstein knew a lot of powerful people, including
Bill Clinton, and that if I didn't do what Mr. Epstein wanted, I would not be able to
have any job in the industry. I was so scared, I couldn't wait to get out of there
and I left. I took the train home. I had spent all of my savings getting Victoria's
Secret lingerie to prepare for what I thought would be my audition, but instead it
seemed like a casting call for prostitution. I felt like I was in hell.
JANE DOE
REPRESENTED BY ATTORNEY GLORIA ALLRED
AUGUST 27, 2019
2 I Page
EFTA00017103


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 18, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
by:
Enclosure
EFTA00016793


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=== Page 1 ===
From:
To:
Subject:
FW: Ghislain Maxwell Meeting recap
Date:
Tuesday, August 11, 2020 5:46:57 PM
Importance:
High
From:
Sent: Thursday, January 16, 2014 6:10 PM
Subject: Ghislain Maxwell Meeting recap
Importance: High
15mm at JPM coming here
10 is invested and 5 in cash she will have
get us copies of the statement and begin
the process
DOES NOT WANT ANY LOCK UP said that is why she is not married
Signing a deal to make anywhere between 1-4 million with a hedge fund that uses maritime
activity to make decision on investing he has been running his own money and is being
backed by a who who, worked for Obama
Spend 500k now and would like to spend another 500 k and wants to die with a Penny No
heirs
Wants
Banking
Checks
Credit Cards
Her company cash Terremar kept here
House accounts
Assistant will have POA on everything
May sell her Townhouse for 17mm
She would like us to
- Sign up for Terremare project
- Introduce Diligence on the fund she may join
- Introduce her to
arounds Philanthropy
Managing Director = Investments
Private Wealth Advisor
UBS Private Wealth Management
SDNY_GM_02742187
EFTA00016034

=== Page 2 ===
New York, NY. 10171
http://financialservicesinc.ubs.com/teaml
Please be advised that this e-mail is not an official transaction confirmation. The official confirmation of this transaction will be sent to you via
regular mail.
SDNY_GM_02742188
EFTA00016035


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: AG Briefing Book
Date: Wed, 24 Jun 2020 21:26:36 +0000
Attachments: AS_AG_Briefing_Book_(as_of_6.24.20)_(final).pdf;, COVID_Filings_Comparison.pdf
Here's the final version of the briefing book for tomorrow. The only addition is the other attachment here, reflecting our
charging stats from last year and this year to illustrate the COVID impact (and our productivity despite it). These are all in
the hard copy binder. Good luck tomorrow-please let me know if there's anything else I can do to help you prepare.
EFTA00015686


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=== Page 1 ===
From:
To:
Subject: RE: Language to include
Date: Thu, 02 Jul 2020 13:54:54 +0000
is cross-referencing the FBI list against hers right now and will call me when she's done with any issues
From:
Sent: Wednesday, July 01, 2020 22:27
To:
is
Subject: FW: Language to include
could you please take on this project of making sure the victim info in the database is accurate for the letter that will
go out? I can't tell if this email is just meant to supplement the data we already have, or if they're sending this as the
proposed list (which would be strange, since it has our statutory victims on it). Thanks.
From:
Sent: Wednesday, July 1, 2020 9:37 PM
To:
is
is
>;
Cc:
Subject: Re: Language to include
Good Evening,
SA
has identified each of these names on the attached spreadsheet as victims in the original case
against Jeffrey Epstein. Included in the attached document is victim contact information as well as attorney
information regarding representation and contact information. This is a comprehensive list.
Lastly, would you be able to send your draft language for the VNS notifications?
Thank you,
Program Manager
FBI Victim Services Division
From: A
Sent: Monday, June 29, 2020 9:05 AM
To:
Cc:
EFTA00016455

=== Page 2 ===
Subject: Language to include
Good Morning,
I hope each of you had a good weekend. Please find language below that has been approved by FBI NY, VSD
executive management and our OGC rep. I'm more than happy to have a call if you would like to discuss.
The FBI's Victim Services Division (VSD) is committed to providing services and support to victims of crimes
committed by Jeffrey Epstein. Though this particular indictment is focused on specific individuals, you are still
entitled to your rights, resources, and referrals as a federal victim independent of this indictment. An overview
of these services is available at www.fbi.gov/resources/victim-services. If you would like to speak with a Victim
Specialist, or if you have any questions regarding your rights to victim services and referrals, please email
victimservices@fbi.gov.
Thank you,
Program Manager
FBI Victim Services Division
EFTA00016456


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Foy
Date: Thu, 06 Feb 2020 16:59:53 +0000
Wait, he hadn't booked anything yet?? Ok, that is WAY less sympathetic. I assumed that everything was booked!
From:
(USANYS)
Sent: Thursday, February 6, 2020 11:56 AM
To:
(USANYS)
Subject: Foy
https://nypost.com/2020/01/30/lawyer-for-epstein-guard-has-shouting-match-with-judge-over-vacation-plans/
https://www.nydailynews.com/new-york/ny-epstein-guards-attorney-vacation-judge-20200130-
kztnvysh4ffw3ea4puhcnjh7qy-story.html
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00016827


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=== Page 1 ===
From: Michael Bachrach
To:
(USANYS)"
)"
Cc: Tony Ricco
>, BRUCE KOFFSKY
, "Kenneth J.
Montgomery Esq"
Aida Leisenring
, "Michael Bachrach"
Subject: Fw: Statements by Mr. Tartaglione
Date: Tue, 19 Nov 2019 19:19:57 +0000
Hi
and
Bruce B. has brought the following exchange to my attention. Yes, to the extent the request has been
made to you please consider it as a Rule 16 request as we view this information as discoverable as
Rule 16 material as to the penalty phase.
Also, in light of your offer, we will hold off for now on pursuing the request with the MCC/BOP to avoid
duplicative efforts. We appreciate your assistance, as your aid could certainly speed things along.
--Michael
Michael K. Bachrach, Esq.
276 Fifth Ave., Suite 501
New York, NY 10001
tel:
fax:
cell:
All other email to:
Forwarded Message
From: Bruce Barket
To: Michael Bachrach
Sent: Tuesday, November 19, 2019, 07:38:07 AM EST
Subject: FW: Statements by Mr. Tartaglione
Received this
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
www.barketepstein.com
EFTA00015932

=== Page 2 ===
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is
not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any
review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received
this communication in error, please notify us immediately by telephone or email and immediately delete this message and
all its attachments
From:
(USANYS) [mailto:
Sent: Monday, November 18, 2019 5:37 PM
To:
Bruce Barket;
)
Cc: Aida Leisenring
Subject: RE: Statements by Mr. Tartaglione
Bruce - To the extent your request is to the MCC/BOP, the request is governed by the procedures set forth below in
email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see what statements are in
our possession and gather and produce them to you by the end of the week. The production will be pursuant to the
protective order in this case.
Assistant United States Attorney
From:
Sent: Monday, November 18, 2019 8:50 AM
To: Bruce Barket
i
(USANYS)
i
Cc: Aida Leisenring
Subject: Re: Statements by Mr. Tartaglione
Hi Bruce,
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for
the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through the
USAO.
Thank you,
>>> Bruce Barket
11/17/2019 5:03 PM
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or
the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt. Pease provide the record of
any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any recording of any such
statements.
EFTA00015933

=== Page 3 ===
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road , Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is
not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any
review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received
this communication in error, please notify us immediately by telephone or email and immediately delete this message and
all its attachments
EFTA00015934


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014300.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) 3"
To:
(USANYS)"
) 1"
Cc:
"
(USANYS)"
Subject: RE: Epstein
Date: Fri, 28 Jun 2019 22:35:07 +0000
Importance: Normal
Yes - usually just once something is seized or someone is charged, but each case gets a paralegal for forfeiture support,
based on unit. For PC it's
so she can do anything that's needed on the Epstein forfeiture side of Epstein.
Co-Chief, Money Laundering and Transnational Criminal Enterprises Unit
Asset Forfeiture Coordinator
United States Attorney's Office
New York
From:
(USANYS)
Sent: Wednesday, June 26, 2019 6:12 PM
To:
(USANYS) 3
is
) 1
Cc:
(USANYS)
^
Subject: Epstein
Do you guys still assign each case to a paralegal? If so, will someone be working on Epstein?
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00014300


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=== Page 1 ===
From: "etravelservices@
To:
@usdoj.gov>,
Subject: Final Voucher 10416822-1(1) approved by
now awaiting further
approval
Date: Fri, 26 Jul 2019 12:20:52 +0000
Importance: Normal
Dear
Final voucher 10416822-1(1) has been approved by
, now awaiting further approval.
Trip ID: 10416822-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYS13654 - U.S. V. Epstein (2018R01618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-07-11 - 2019-07-12
Current status: Pending Voucher Approval
Voucher total expenses: 779.97
Estimated trip cost: 1050.66
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00014529


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c0:
=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
-
Date: Mon, 29 Jul 2019 19:21:49 +0000
Attachments:
wav
Time: Jul 29, 2019 3:21:49 PM
Click attachment to listen to Voice Message
EFTA00015708


c1: EFTA00014471
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014471.pdf
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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
,
)"
Subject: RE: photos
Date: Tue, 16 Jul 2019 18:01:38 +0000
Importance: Normal
Attachments: 2019-07-16, JE,_detention_submission.docx
and
The letter is attached for your review-the team has discussed. Thanks.
From:
Sent: Tuesday, July 16, 2019 1:46 PM
To:
Cc:
(USANYS)
is
is
(USANYS)
Subject: Re: photos
I can look now too
Sent from my iPhone
On Jul 16, 2019, at 13:41,
)
wrote:
Just finished reviewing and discussing my thoughts with
now.
From:
(USANYS)
Sent: Tuesday, July 16, 2019 1:39 PM
To:
is
(USANYS)
Cc:
is
Subject: RE: photos
Are
and
able to look now? If it will be a while, we will review the interim version.
From:
Sent: Tuesday, July 16, 2019 1:32 PM
To:
(USANYS)
Cc:
(USANYS)
is
)
>;
Subject: RE: photos
Just sent to
and
for a first look, and will circulate shortly after I input their comments. Thanks.
From:
(USANYS)
Sent: Tuesday, July 16, 2019 1:19 PM
To:
EFTA00014471

=== Page 2 ===
Cc:
(USANYS)
i
>;
Subject: Re: photos
Okay. What is timing on a draft?
Sent from my iPhone
On Jul 16, 2019, at 12:07 PM,
wrote:
FYI, I spoke with Judge Berman's chambers and the clerk told me the Judge does not want to see photographs (he did
not explain), so we are not going to bring them to chambers.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00014472


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=== Page 1 ===
Rick V. Haas
701 Experian Parkway
Custodian of Records
Allen, Texas 75013
Experian Consumer Affairs
www.experian.com
experian.
EFTA00016324

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Experian Information Solutions, Inc.
701 Experian Parkway
Allen, TX 75013
Attn: Subpoena Compliance Dept.
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan. City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b), 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please
contact Forensic Accountant
or Special Agent
with any questions.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 16, 2019
July
GEOFFREY S. BERMAN
STATES
DISTRICT
United States Attorney for the
Southern District of New York
Luly
Assistant United States Attorney
THE
One St. Andrew's Plaza
New York. New York 10007
Telephone:
EFTA00016325

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Experian, dated August 16, 2019)
Please provide any and all credit reports, fraud alerts, and related documents pertaining to the
following individuals listed, including all known accounts and lines of credit, addresses and
personal identifying information, and all credit inquiries regarding the individuals and the
addresses provide at the time of said inquiry regardless of whether accounts were open.
Please utilize the identifiers below:
NAME
GHISLAINE MAXWELL
DOB
/1961
SSN
ADDRESS
BOSTON, MA
NEW YORK, NY
PHONE
NAME
GHISLAINE MAXWELL
DOB
1961
N.B.: Personal appearance is not required if the requested records are (1) produced by on or
before the return date to Special Agent
Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephone
bv; and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
Please contact Forensic Accountant
at
or Special Agent
at
with any questions.
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
3
EFTA00016326

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
Rick V. Haas
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant
United States Attorney
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
8/27/19
-
(date)
Rin V. Haar
(signature of declarant)
Rick V. Haas, Custodian of Records
(name and title of declarant)
Experian
(name of business)
701 Experian Parkway
(business address)
Allen TX 75013
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind. whether or not conducted for profit.
EFTA00016327

=== Page 5 ===
Credit Profile from Experian Inc.
Page 1 of 2
experian
TTX2 RHS 8999837** MAXWELL, GHISLAINE
CA-
/BOSTON
MA;PA
/NEW YORK NY;Y-1961;K-PH,H-Y,T-2B
PAGE 1 DATE 8-27-2019 TIME 16:43:08 V301 TMA1
GHISLAINE MAXWELL
SS:
E: J EPOTEINA CO
DOB:
/61
RPTD: 1-96 I
BOSTON MA 021143252
RPTD: 5-18 TO 6-18 U 2X
E: J EPSTEIN AND COMPNY
LAST SUB: 1229200
RPTD: 1-95 I
TEANECK NJ 076665529
RPTD: 7-16 U
TEANECK NJ 076660308
RPTD: 5-16 TO 6-16 U 1X
*GHISLAINE BORGERSON
DEMOGRAPHICS
PH:
UC
PH:
UR
PH:
UR
GEO:
FRAUD SHIELD SUMMARY
INPUT SSN ISSUED 1990-1993
FROM 5-01-19 INQ COUNT FOR SSN=0
FROM 5-01-19 INQ COUNT FOR ADDRESS=0
TRADES
SUBSCRIBER
OPEN
AMT-TYP1
AMT-TYP2 ACCTCOND
PYMT STATUS
SUB# KOB TYP TRM ECOA BALDATE
BALANCE
PYMT LEVEL MOS REV
PYMT HISTORY
ACCOUNT #
LAST PD
MONTH PAY
PAST DUE
MAXIMUM
BY MONTH
*BANK OF AMERICA
3-09
$6,000-L
$1,679-H
CLOSED
CURR ACCT
1230206 BC CRC REV
1 10-12-11
$0
10-11
(30)
BCCCCCCCC---C
9-11
$47-A
CC-----CCCCC
** ACCOUNT CLOSED AT CONSUMER'S REQUEST **
*UBS BANK USA
2-14
$35,000-L
$3,151-H
PAID
CURR ACCT
1922551 BB FSC REV
1
7-25-19
7-19
(65)
BCCCCC000C0CC
5-19
CC0000CCCCCC
** ACCOUNT CLOSED AT CREDIT GRANTOR'S REQUEST **
JPMCB CARD
1-96
$12,200-L
$12,644-H
PAID
CURR ACCT
3182310 BC CRC REV
1
3-08-15
3-15
(99)
BCCCCCCCCCCCC
3-14
CCCCCCCCCCCC
*ELAN FINANCIAL SERVICE
10-04
$23,000-L
PAID
CURR ACCT
2205270 BC CRC REV 1 7-31-12
7-12
( 1) B
** ACCOUNT CLOSED AT CONSUMER'S REQUEST **
https://ea2.ec.experiannet.com/jAccess/inquiry
8/27/2019
EFTA00016328

=== Page 6 ===
Credit Profile from Experian Inc.
Page 2 of 2
*AMEX
10-91
$19,504-H
PAID
CURR ACCT
1229200 BC CRC
1
1 10-02-10
10-10
( 1) B
** ACCOUNT CLOSED AT CONSUMER'S REQUEST **
*AMEX
5-91
$19,184-H
PAID
CURR ACCT
1229200 BC CRC
1
1
7-02-10
7-10
( 1) B
** ACCOUNT CLOSED AT CONSUMER'S REQUEST **
*CAPI/SAKS
6-15
$40,000-L
$3,292-H
OPEN
CUR WAS 30
1195162 DC CHG REV
1
8-15-19
$0
2-16
(50)
0000000000000
5-19
$31
1-16/1
CCCCCCCCCCCC
AMEX
7-91
$102,243-H
OPEN
CURR ACCT
1229200 BC CRC
1
1
8-18-19
$102,243
8-19
(99)
CCCCCCCCCCCCC
UNK
CCCCCCCCCCCC
*USAA SAVINGS BANK
4-12
$35,000-L
$32,899-H
OPEN
CURR ACCT
3271200 BC FSC REV
3
7-26-19
$5,892
7-19
(88)
CCCCCCCCCCCCC
7-19
$22,307-A
CCCCCCCCCCCC
.. ACCOUNT PREVIOUSLY IN DISPUTE - INVESTIGATION COMPLETE,
REPORTED BY DATA FURNISHER **
INQUIRIES
CITIBANK NA., BEST BUY 2-17-19 2145203 BB
CONSUMER ASSISTANCE CONTACT: EXPERIAN
701 EXPERIAN PARKWAY, PO BOX 2002, ALLEN, TX 75013
END -- EXPERIAN
DIRECT CHECK
SUBCODE SUBSCRIBER
TELEPHONE
ADDRESS
CITY
ST ZIP
1229200 AMEX
PO BOX 297871
FORT LAUDER FL 33329
1230206 BANK OF AMERICA
PO BOX 982238
EL PASO
TX 79998
1195162 CAP1/SAKS
3455 HIGHWAY 80 W
JACKSON
MS 39209
2145203 CITIBANK NA., BES BYMAILONLY
701 E 60TH ST N
SIOUX FALLS SD 57104
2205270 ELAN FINANCIAL SE
PO BOX 108
SAINT LOUIS MO 63166
3182310 JPMCB CARD
PO BOX 15298
WILMINGTON DE 19850
1922551 UBS BANK USA
299 S MAIN ST STE 2
SALT LAKE C UT 84111
3271200 USAA SAVINGS BANK BYMAILONLY
PO BOX 47504
SAN ANTONIO TX 78265
END -- EXPERIAN DIRECT CHECK
Top of page I Back to Entry Form
Copyright Experian Information Solutions, Inc. All rights reserved.
https://ea2.ec.experiannet.com/jAccess/inquiry
8/27/2019
EFTA00016329


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE:
Date: Tue, 16 Jul 2019 19:25:33 +0000
Importance: Normal
Sure, I can walk over. This will be quick.
From:
(USANYS)
Sent: Tuesday, July 16, 2019 3:25 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE:
I'm headed into a verdict report and then a brass meeting, but can meet you briefly on 8 beforehand if you want.
From:
(USANYS)
Sent: Tuesday, July 16, 2019 3:03 PM
To:
(USANYS)
Cc:
(USANYS)
Subject:
Apropos of our conversation a few hours ago, I just got a call from
and
who have been retained
to represent
one of the former DOJ folks mentioned on the record yesterday by defense counsel as
having been involved in reviewing the Epstein NPA. She is quite upset about the press coverage and is considering making
a public statement. Would be interested in your thoughts if you have a few minutes to discuss.
EFTA00016745


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Tue, 13 Aug 2019 22:18:54 +0000
Thanks for checking in on this - we expect to continue to bring in victims and witnesses in connection with the active
grand jury proceedings, under the same USAO number as before
(
). Some individuals will be subject to grand
jury subpoenas, and others may be meeting with us in lieu of testifying before the grand jury. We can advise if we believe
we need to use USAO funds, or if other issues arise, but we can confirm we do still have an active grand jury investigation
(including prospective grand jury testimony).
thanks very much,
From:
Sent: Tuesday, August 13, 2019 17:38
To:
)
Subject: FW: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
,
What case am I using to bring witnesses into SDNY. I can only bring people in for GJ, pretrial, trial and sometimes pre GJ.
For the last three witnesses it was pre-trial. But that was when we had an open indictment.
If you are interviewing more people in an investigation you are going to have to travel to them.
I am not giving anyone a hard time I just need to follow the rules.
Please let me know.
From: Colleen Mullen
Sent: Tuesday, August 13, 2019 5:20 PM
To:
Cc: Teri Gibbs
; Arick Fudali
Subject: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear
I spoke to
yesterday and she confirmed that she is still interested in speaking with our clients.
S is still available to meet with prosecutors on August 26, 2019 at 12:00 p.m. in New York.
Please let me know what information you need from me to arrange flights/hotel stay for
Additionally, you previously mentioned that there may be counseling resources available for our clients. Could
you send me that information as well?
Thank you,
Best,
Colleen
Colleen M. Mullen, Esq.
EFTA00017105

=== Page 2 ===
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private
information. If you have received it in error, please notify the sender immediately and delete the original. Any
other use of the email by you is prohibited.
EFTA00017106


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 18, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing discovery materials pertinent to Ghislaine Maxwell
(02879-509) is
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
EFTA00016794


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=== Page 1 ===
10/6/21, 12:37 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a search of the III based on:
FINGERPRINT CLASS
PATTERN CLASS
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/1
EFTA00015126


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=== Page 1 ===
From:
To:
Subject: Maxwell, Ghislaine_Transcript (04-22-16).pdf
Date: Fri, 29 May 2020 18:28:33 +0000
Attachments: Maxwell,_Ghislaine_Transcript_(04-22-16).pdf
EFTA00016452


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=== Page 1 ===
From:
"
To:
Cc:
"
Subject: RE: Epstein
Date: Fri, 07 Dec 2018 16:03:57 +0000
Importance: Normal
My office; gen locked
From:
Sent: Friday, December 7, 2018 11:03 AM
To:
Cc:
Subject: RE: Epstein
suggests going to
office because his speakerphone is good. Headed there now.
From:
Sent: Friday, December 07, 2018 11:00 AM
To:
is
Cc:
is
Subject: RE: Epstein
Meeting in my office? Or
?
From:
Sent: Thursday, December 06, 2018 9:25 PM
To:
Cc:
is
)
is
Subject: Re: Epstein
I can call in at 11:00.
Sent from my iPhone
On Dec 6, 2018, at 9:22 PM,
wrote:
Ok for me.
Sent from my iPhone
On Dec 6, 2018, at 7:12 PM,
wrote:
Good for me.
From:
Sent: Thursday, December 6, 2018 7:08 PM
EFTA00014307

=== Page 2 ===
To:
Cc:
is
is
Subject: Re: Epstein
How about 11:00?
Sent from my iPhone
On Dec 6, 2018, at 7:04 PM,
wrote:
In case you haven't seen, various lawmakers are now calling on DOJ to explain the Epstein NPA. If you have a few
minutes tomorrow, would be helpful to touch base.
https://www.nbcnews.com/news/us-news/lawmakers-demand-probe-sex-offender-jeffrey-epstein-s-sweetheart-
deal-n944516
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Deutsche Bank Production
Date: Wed, 20 Nov 2019 14:29:54 +0000
Attachments: 2019.11.19_DB_Submission_to_SDNYpdf
Following up on last night's submission, we realized that one of the files included in the Sharefile link we provided was
mislabeled. The correct file was provided, but the file name was in error-a corrected copy is attached for your records.
Apologies for any confusion, and please let us know if you have any questions.
Best,
From:
Sent: Tuesday, November 19, 2019 10:35 PM
To:
Cc:
<jdi
Subject: Deutsche Bank Production
On behalf of our client, Deutsche Bank, the link below contains an additional production of documents in response to
your July 11, 2019 subpoena. Also attached is the accompanying cover letter for today's production, as well as an
updated version of the production index we previously provided. I will send the password shortly under separate cover.
Please do not hesitate to reach out if you have any questions.
Regards,
Citrix Attachments
Expires May 17, 2020
2019.11.19 DB Submission to NYAG.pdf
155.3 KB
Appendix A.xlsx
229.2 KB
Appendix B.pdf
174.5 KB
EFTA00015935

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Citrix Attachments
Expires May 17, 2020
DB-SDNY-Prod011.zip
287.3 MB
Download Attachments
uses Citrix Files to share documents securely.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
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=== Page 1 ===
L-Tier
Inmate
Number
Desilva, Michael
55381-066
Brown, Chad
70786-050
Fernandez, Leonardo
86824-054
Rivera, Jose
72008-054
Babdrow, Lorenzo
76157-054
Reyes, Frankie
79102-054
Jimenez, Edward
79466-054
Rodriguez, Daniel
91278-054
Estevez, Steven
86102-054
Hill, Jaquez
79455-054
Contreras
89520-053
Santos-Felix, Christopher
86638-054
Epstein, Jeffrey
76318-054
Felix
85775-054
G-Tier
Inmate
Number
Hoytt
68152-054
Hossain
87049-054
H-Tier
Inmate
Number
Ochoa
86452-054
Almanzar
85978-054
Fuentes
86368-054
Santiago-Men
80341-083
Durant
86124-054
Davis
89380-053
Reid
85609-054
Kaba
86931-054
Dones
86214-054
Mojica
91268-054
Santiago
08224-082
Latimer
79427-054
Blades
79407-054
Jones
68302-054
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J-Tier
Inmate
Number
Rodriguez
79168-054
Brock
86460-054
Palermo
79166-054
Murray
57497-054
Lans
86357-054
Lovick
86356-054
Ferrer
79793-054
Gonzalez
86825-054
Copper
92299-054
Washington
77510-054
Dockery
60685-050
Butler
86630-054
Perez
78346-054
Avila
86710-054
Robinson
34801-058
K-Tier
Inmate
Number
Kintea
86587-054
Woney
76232-054
Arroyo
86123-054
Deleon
86132-054
Rosa
86324-054
Cave
86164-054
Galan
75775-054
Hemingway
14728-055
Torres
86020-054
Smith
78175-054
Rivera
86225-054
Gonzalez
86617-054
Brissett
76269-054
Romero
74203-054
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M-Tier
Inmate
Number
Gouldbourne
23152-014
Diaz
77930-054
Benjamin
86463-054
Quiroga
86210-054
Vasquez
76290-054
Mickens
86160-054
Garcia
86290-054
Saxon
08765-094
Guillen
08820-070
Vega
79099-054
Grayson
70887-054
Tartaglione
78514-054
McGrier
85989-054
Eke
72418-019
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=== Page 1 ===
From:
(USANYS) 1"
To:
)"
Cc:
(USANYS)"
(USANYS)"
Subject: Worlds colliding - Maxwell and Andrews (kind of)
Date: Mon, 21 Dec 2020 02:38:48 +0000
Attachments: Letter_to_court_12_20_2020.pdf
Hi
- the severed half of Carl Andrews's case is scheduled for trial in mid-February, and lawyers for one of the
defendants in that coming trial have just filed a letter (attached) arguing their client, Justin Rivera, is receiving insufficient
access to discovery at MCC when compared to the access to discovery Maxwell is getting at MDC (see page 4).
Do you have a few minutes to chat before tomorrow at 10:30am (when we next appear before PAE) regarding Maxwell's
access? I'm aware of the obvious differences in institutions (MDC is larger and has more space than MCC) and particular
units (the women's unit at MDC being viewed as particularly spacious with its own library, I think) -- and how these
differences probably allow for Maxwell to have substantially more access than a male inmate at MCC.
Assistant United States Attorney
United States Attorney's Office for the Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Tel:
Cell:
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=== Page 1 ===
From:
)"
To:
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Date: Tue, 17 Dec 2019 14:17:29 +0000
Sounds good!
From:
Sent: Tuesday, December 17, 2019 9:17 AM
To:
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Ok, sounds good. We have 10:30 sonogram tomorrow so I'll meet you up there after.
Co-Chief, Narcotics Unit
From:
Sent: Tuesday, December 17, 2019 9:15 AM
To:
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Thanks again for taking the lead on this stuff. l'll be in a meeting from about 10:30am to 3pm today, but otherwise am
available if there's anything you want to discuss before tomorrow's conference. I have a 10am plea in White Plains
tomorrow, so I'm planning to take the train up.
From: Swergold, Jason (USANYS)
Sent: Tuesday, December 17, 2019 6:47 AM
To: Aida Leisenring <aleisenring@barketepstein.com>
Cc:
>; Bruce Barket <bbarket@barketepstein.com>
Subject: Re: Follow Up on July 23 Incident Sensitive Disclosure Materials
Aida,
To confirm, we are looking into whether video of the hallway, and videos and/or photos of the cell exist. We likely would
make those available for review in the same manner as the report. We are also looking into whether the orange rope was
preserved and if it was, we will let you know our position on whether it can be made available for inspection. As discussed
briefly, since you have reviewed a photograph of the rope, we are not sure the basis for a physical inspection and would
ask you to articulate one for our consideration.
Co-Chief, Narcotics Unit
On Dec 16, 2019, at 16:52, Aida Leisenring <aleisenring@barketepstein.com> wrote:
Hello Jason and Maurene,
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Thank you for taking the time to let us review sensitive disclosure materials in your office on Friday. We appreciate it. I
just wanted to memorialize a few follow-up questions we had.
1. It is our understanding that there is video surveillance in the hallway in or near the tier that was preserved in
reference to the July 23 incident. We would like to see a copy of it.
2. It is our understanding that there may be photographs or a video recording of cell 124 that would have been
taken shortly after the incident. If so, we would like to see them.
3. If the orange rope was preserved, we would like to view it in person.
Jason, I understand that you were not aware of the availability of the above and that you would look into this additional
discovery. I just wanted to memorialize our follow up inquiries for your records.
Lastly, if the items above are available, does your office take a position with respect to our request to view them? We
just need to know so we can plan our next course of action.
See you in Court, and thank you again for your time.
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
666 Old Country Road, Ste 700
Garden City, NY 11530
T
F
Please note that my emailed has changed to:
aleisenring@barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments.
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Jeffrey Epstein devices - privilege review
Date: Fri, 02 Oct 2020 01:01:59 +0000
Embedded: RE:_Jeffey_Epstein_devices__privilege_review.msg
Sender:
Subject: RE: Jeffrey Epstein devices - privilege review
Message-Id:
<CY1P110MB0517A782CE72B358245BE20E8F310@CY1P110MB0517.NAMP110.PROD.OUTLOOK.COM
>
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=== Page 1 ===
From:
To:
Subject: RE: want the bounces for Maxwell?
Date: Mon, 06 Jul 2020 21:21:24 +0000
Done - when we next get a bounce, I'll confirm with you that it worked, and we should be all set.
From:
Sent: Monday, July 06, 2020 17:16
To:
Subject: RE: want the bounces for Maxwell?
Sure, that'd be great. Thanks
From:
Sent: Monday, July 6, 2020 5:15 PM
To:
Subject: want the bounces for Maxwell?
Hey, I think after we indicted Epstein I set up an Outlook rule that automatically forwarded court bounces to you and
- would you like me to do that for Maxwell? No problem at all if not, we're totally happy to just keep you posted,
but if that's helpful let me know.
of New York
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=== Page 1 ===
sa I'm SD exuted
Boss be ght
me whicht to come aut + see
hr who been almost a year- xary
IKUS wy wealthy + might help
up because / hate as ssupo ntment
1 lon must to jit my hopes
my get into or pay for willege
kut it would be really Cool it
it not prenera + even it I +doesn t7
mv, 15 80 effect l get to go see
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=== Page 1 ===
From:
To:
Subject: Accepted: DB/Epstein Meet
Date: Wed, 24 Jul 2019 21:17:46 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
To:
Subject: Acosta Defends Epstein Plea At Labor Committee Hearing - Law360
Date: Thu, 02 May 2019 10:49:45 +0000
Importance: Normal
Acosta Defends Epstein Plea At Labor Committee Hearing
By Vin Gurrieri
https://www.law360.com/articles/1153080/acosta-
defends-epstein-plea-at-labor-committee-hearing
Share us on:
Law360 (May 1, 2019, 6:35 PM EDT) -- U.S.
Secretary of Labor Alex Acosta forcefully pushed
back Wednesday as Democratic lawmakers voiced
concerns that his alleged mishandling of a decade-old
sex crime case against millionaire Jeffrey Epstein
meant he might also let employers off easy for
workplace law violations.
At a wide-ranging hearing before the House
Committee on Education and Labor, lawmakers
quizzed Acosta on a variety of issues facing the U.S.
Department of Labor, ranging from the agency's
budget to regulatory initiatives and enforcement
priorities. But one area where Acosta received
strident criticism was over a nonprosecution deal he
struck with Epstein in a teen sex trafficking case
when he was the U.S. attorney for the Southern
District of Florida about a decade before he became
labor secretary.
U.S. District Judge Kenneth A. Marra found in
February that Acosta and other prosecutors had
misled Epstein's victims about the existence of the
nonprosecution agreement, thereby violating their
right to be informed under the Crime Victims' Rights
Act. That decision came several months after The
Miami Herald published an investigative series that
said Acosta gave Epstein the deal in exchange for a
guilty plea to lesser state charges. The unusually
EFTA00014454

=== Page 2 ===
lenient agreement called off potential federal charges
not only against Epstein but also against alleged co-
conspirators.
Democratic Rep. Frederica Wilson of Florida
expressed concern during Wednesday's hearing that
Acosta's alleged mishandling of the Epstein case was
an indication that he won't adequately protect
workers' interests over those of industry.
But that assertion drew a sharp rebuke from Acosta,
who said the U.S. Department of Justice has long
taken the position that the Crime Victims' Rights Act
wasn't violated in the Epstein case.
"I understand that the judge disagreed with the
[DOJ's] position, but we acted consistent with DOJ
protocol, rules and regulations and that's the position
of the department based on my understanding of the
litigation," Acosta said, adding that the DOJ's
position hasn't changed across different
administrations and attorneys general.
"This matter was appealed all the way up to the
deputy attorney general's office, and not because we
weren't doing enough, but because the contention was
that we were too aggressive," Acosta added.
Besides the Epstein case, Acosta also fielded pointed
questions from committee Democrats on various
recent regulatory initiatives by the DOL, with most
of the queries focusing on the Labor
Department's recent proposal to overhaul its white-
collar overtime exemption regulations.
The proposed regulation would update the Fair Labor
Standards Act's overtime exemptions for executive,
administrative and professional, or EAP, workers,
replacing a previous version issued by the Obama
administration.
EFTA00014455

=== Page 3 ===
If it is finalized without major changes, the rule will
hike the DOL's salary threshold for white collar
workers to qualify for one of the EAP exemptions to
$35,308 per year or $679 per week - up from the
$23,660 annual salary that was set when the rule was
last updated in 2004, but lower than the $47,000
cutoff the Obama administration had proposed in
2016.
Rep. Virginia Foxx of North Carolina, the top
Republican on the committee, expressed concern that
the Obama-era overtime regulation is still pending at
the Fifth Circuit and could conceivably be revived
before the DOL is done with the current rulemaking
process to replace it.
Acosta, however, sidestepped her request for
"assurances" that the proposed replacement rule
would be finalized "in a timely manner," with the
labor secretary simply reiterating that the proposed
regulation has been issued and the public notice-and-
comment period is ongoing.
In response to a question on the overtime rule from
Democratic Rep. Mark Takano of California, Acosta
defended the DOL's decision to appeal a ruling that
blocked the Obama administration's version of the
rule - the same one the DOL is currently trying to
replace - to protect the agency's ability to issue such
a rule at all.
"I think it's important when these rules are called into
question, the U.S. government should defend them
where appropriate," Acosta told Takano. "We can
disagree with the policy underlying the rule and we
can still appeal the rule."
In a notable regulatory tidbit, Acosta divulged to
lawmakers that the agency is working with the U.S.
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=== Page 4 ===
Securities and Exchange Commission on a new
fiduciary rule.
An Obama-era version of the rule issued by the DOL
requiring retirement advisers to put their clients'
interests before their own when selling retirement
investments was struck down by the courts.
"Based on our collaborative work we will be issuing
new rules in this area," Acosta said, but declined to
offer a time frame for when any such rules might be
issued.
Acosta also addressed several other hot-button
employment topics during the hearing. He weighed in
on the U.S. Supreme Court's landmark decision last
year in Janus V. AFSCME
which deemed it
,
unconstitutional for public-sector unions to collect
so-called agency fees from nonunion workers that
cover the costs associated with collective bargaining
without their explicit consent.
The labor secretary told lawmakers he believes Janus
was a "correct and appropriate" decision, and that the
DOL is enforcing the law in the wake of Janus "to the
extent that it comes within our authority."
Acosta also responded to a question about the
minimum wage from the Education and Labor
Committee chairman, Democratic Rep. Bobby Scott
of Virginia, by saying the Trump administration
doesn't "support a change to the federal minimum
wage at this time."
--Editing by Marygrace Murphy.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: WG: introduction to Mr Peter Goldscheider, fouding partner of EPIC Invest investment bank
from Vienna, Austira, mainly focused on Eastern European investments and advisory)
Date: Tue, 28 Jan 2020 15:27:56 +0000
you do get the strangest emails. Passing up to the PC chiefs for their due consideration.
From
(USANYS)
Sent: Tuesday, January 28, 2020 10:25 AM
To:
(USANYS)
Subject: Fwd: WG: introduction to Mr Peter Goldscheider, fouding partner of EPIC Invest (investment bank from Vienna,
Austira, mainly focused on Eastern European investments and advisory)
Sent from my iPhone
Begin forwarded message:
From: Margareth Puttini
Date: January 28, 2020 at 7:06:01 AM EST
To:
Cc:
Subject: WG: introduction to Mr Peter Goldscheider, fouding partner of EPIC Invest (investment bank
from Vienna, Austira, mainly focused on Eastern European investments and advisory)
Mr. Geoffrey S. Berman
Maybe this Infos could help you in the case of Jeffrey Epstein.
Epstein had an austrian passport and worked also for the hapsburg Group (manafort Alfred gusenbauer and Peter
goldscheider)
Peter Goldscheider is the key Person in the ukraine affair, with all companies, from kinto ukraine till rivada Network in
USA.
He is a Cold blood Killer.
Alvaro Alves was his victim in New York on 28.11.2017
Interesting also is the circunstances of 2 "suicides"
jeffrey epstein
both had contact to habspurg group
Gabriel Lansky was the lawyer figthing against Rachat Alijew. He is also a Killer.
respectfully,
ihre dr. puttini
Von: Margareth Puttini
Gesendet: Samstag, 7. Dezember 2019 13:43
An:
EFTA00016805

=== Page 2 ===
Betreff: introduction to Mr Peter Goldscheider, fouding partner of EPIC Invest ( investment bank from Vienna, Austira,
mainly focused on Eastern European investments and advisory)
Dear David,
The most interesting thing is what we will do with mioty and azure.
The mission in Alta Floresta was positive. And Jedi is done.
About something we will do not talk about, but you should know.
In order to give you an idea how 2 boys were planning to crash europe and the euro... maybe also dollars.
It was a coincidence that I got in contact with this plan.
Only due to my expertise in carbon market.
Alvaro Alves died in 28 november 2017. Strange.
His case is under investigation by Letitia James.
As you see Mr. Goldscheider has also kinto.com, ukraine company
Mr. Dmitry Firtash was working with him since some years.
https://en.interfax.com.ua/news/economic/479485.html
https://www.occrp.org/en/investigations/before-campaigning-for-trump-manafort-plotted-to-rig-ukraine-
telecoms-deal-leaked-emails-show
Maybe Mr. Trump could also be more intelligent and know that maybe Mr. Goldscheider was only using
him to get equitablesolution done. He runs also rivada networks
https://www.rivada.com/#our-people
As we could avoid brexit - Mr. Merkel was working hardly on it (my friend Dominique Ristori was talking to
her in march 2019) the all project equitable solution has been put out of force, in october 2019, Mr. Anthonny
Scaramucci (friend of Soros and Goldscheider) was trying also to impeach Trump.
As you saw in the investigations about Jeffrey Epstein, our mobiles are unsafe.
https://www.mintpressnews.com/cia-israel-mossad-jeffrey-epstein-orwellian-nightmare/261692/
Von: Alves, Alvaro
Gesendet: Dienstag, 1. November 2016 20:05
An:
Cc: 'Goldscheider, Peter'; Kuffner, Gudrun
Betreff: introduction to Mr Peter Goldscheider, fouding partner of EPIC Invest ( investment bank
from Vienna, Austira, mainly focused on Eastern European investments and advisory
Dear Mr. Jorge Costa e Silva,
As per our conversation yesterday, I would like to introduce you to Mr. Peter Goldscheider, founding partner of EPIC Invest, an
investment bank/private equity group based in Vienna, Austria, that focus its investments in Eastern European countries.
Mr. Goldscheider* ( pls see his bio below) , is a prominent financier, and one of the largest players in past privatizations of Eastern
European companies. Pls see the website for his investment bank EPIC Invest.
http://www.epicinvest.com/about-epic/overview
A history of his past deals can be found under M references" in the website.
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=== Page 3 ===
I mentioned to him about Mr .Carlos Sanchez investment in the pharmaceutical CO. Galenika of Serbia, , and he will be delighted to
meet you and him, as EPIC has a very good team of professionals in Beograd.
Also, he has a very interesting investment in Montenegro ( pls see presentation in PDF attached), that may fit Mr. Sanchez's
investment goals.
Please see below a list of his other investment opportunities in the US, Croatia and Montenegro.
1.
Information on Peter's major US investment can be found at www.rivada.com
2.
Information on our Croatian tourism investment is available at www.valamar.com
3.
Lastly, I am attaching a description of the Montenegrin high-end hospitality investment, which is
to become Auberge Resorts' first venture into Europe. The particular appeal of this project lies in the
team composition, which can be seen as a seal of quality, opening up the local market to an entirely
new and high-end customer segment. Please find more information on Auberge at
https://aubergeresorts.com/
Montenegro disposes of the arguably most beautiful coastline in the region and has created
investment conditions, which guarantee maximum protection to FDI. In addition to these generally
favorable prerequisites to a successful investment we should also mention that the political backing
has been ensured through extensive diplomatic exchange especially with the USA.
PETER GOLDSCHEIDER, MANAGING PARTNER
Peter Goldscheider has more than 25 years experience as a senior executive in the securities and finance industry.
Before jointly establishing EPIC with Gustav Wurmböck, he was Vice President for Marketing and Sales and Board
Member Board of Zürich Kosmos Insurance Company in Austria, and he began his professional career with IBM
Austria, serving in a number of executive positions.
His professional activities included serving as Chairman of the Board of EPIC (Advisors) Russia Ltd. and I. EPIC
Holding, Prague and as President of the Board of KINTO Investments & Securities, Kyiv (www.kinto.com); he also was
co-founder and board member of Invision AG, a Zug-based investment group focusing on leading edge technology and
innovation companies (www.invision.ch). Peter Goldscheider is a board member of Rivada Networks
(www.rivada.com).
Mr. Goldscheider also served a Chairman of the Supervisory Board of Ukrtelecom from August 2011 until October
2013, since the majority (92,97%) of Ukrtelecom was acquired by ESU Ltd., EPIC's subsidiary in Ukraine.
Mr. Goldscheider received his Ph.D. in Law from the University of Vienna Law Faculty and attended the IBM/Harvard
Business School joint senior managers program. He is the recipient of the Golden Order of Merit of the City of Vienna
Dear Peter,
Please meet Mr. Jorge Costa e Silva, business partner of Mr. Carlos Sanchez, owner of the largest pharmaceutical company in Brazil
with investments in the US and Europe.
http://www.gruponc.net.br/negocios/nc-farma/ems
www.bracepharma.com
Mr. Costa e Silva and Mr. Sanchez will be in Beograd in November, and would be interesting if you could meet while they are in the
region.
Best rgds,
Alvaro M. Alves
Associate Director - Investments
Oppenheimer & Co. Inc.
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=== Page 4 ===
200 Park Avenue, 24th Floor
New York, NY 10166
Phone:
Toll Free:
Fax
Assistants / Assistentes
John Reinhardt
Nicholas Demczar
This communication and any attached files may contain information that is confidential or privileged. If this
communication has been received in error, please delete or destroy it immediately. Please go to
www.opco.com/EmailDisclosures
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From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
"Mark S. Cohen"
,
Bcc: "USAHUB-USAJournal111"
Subject: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 01:41:48 +0000
Embedded: Ghislaine_Maxwell_02879-509.msg
Sender:
Subject: Ghislaine Maxwell 02879-509
Message-Id: <BFE5EE77-6826-4841-B3B3-B97BAE10F76B@mac.com>
Recipient
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From:
To:
Subject: Sd fl Epstein
Date: Tue, 16 Apr 2019 18:59:16 +0000
Importance: Normal
fbi chief counsel for Florida office
Sent from my iPhone
EFTA00015562


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=== Page 1 ===
JANE DOE #4
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 4
4/25/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 6
5/3/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 8
5/14/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 9
5/20/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 11
6/3/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 14
6/11/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 15
6/20/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 19
7/10/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 24
7/18/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 25
7/22/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 29
7/22/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 30
8/4/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 37
8/25/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 43
10/3/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 47
10/30/04
Conspiracy to entice a minor to
engage in prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 3
JANE DOE #4
EFTA00016016

=== Page 2 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 48
11/4/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 77
1/4/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 87
1/22/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 101
2/14/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 106
2/24/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 114
3/18/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 116
3/29/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 127
4/11/05
Conspiracy to entice a minor to
engage in prostitution
Ct. 8
4/25/04 -
EPSTEIN
Enticement of a minor to engage in
6/29/05
prostitution
Ct. 17
5/21/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 18
6/4/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 19
6/20/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 2 OF 3
JANE DOE #4
EFTA00016017

=== Page 3 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
Ct. 22
7/22/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 23
8/6/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 28
11/5/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 35
1/6/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 40
2/24/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 43
3/31/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 52
4/25/05 -
EPSTEIN
Recruiting, enticing, providing, or
6/29/05
obtaining a person, knowing that she
is a minor and will be caused to
engage in a commercial sex act
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 3 OF 3
JANE DOE #4
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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
, Christian Everdell
Subject: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
Date: Fri, 29 Oct 2021 15:50:59 +0000
Inline-Images: Screen_Shot_2021-10-29_at_10.01.52_AM.png; Screen_Shot_2021-10-
29_at_10.01.38_AM.png
Further my earlier email today, as of 10:30 a.m., USPO tracking lists the following 4 items of legal mail
"Available for Pickup" and does not indicate that MDC has retrieved or received them.
Ms. Maxwell has not received legal mail in more than a week.
Please confirm IMMEDIATELY the status of these items on your end.
Failure to response today will result in the filing of an order to show cause requiring your presence in Court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00016259

=== Page 2 ===
Tracking Number: EJ699436400US
Scheduled Delivery by
Status
SATURDAY
Available for Pickup
16
by
October 19. 2021 at 6:51 am
OCTOBER
6:00pm
BROOKLYN, NY 11232
2021 1
Get Updates
Available for Pickup
See More
Tracking Number: EJ699436435US
Scheduled Delivery by
Status
THURSDAY
Available for Pickup
14
by
October 15, 2021 at 7:55 am
OCTOBER
BROOKLYN, NY 11232
2021 1
6:00pm 1
Get Updates
Available for Pickup
See More
EFTA00016260

=== Page 3 ===
Tracking Number: EJ699436427US
Scheduled Delivery by
Status
THURSDAY
Available for Pickup
28
by
October 28, 2021 at 10:59 am
OCTOBER
6:00pm
BROOKLYN NY 11232
2021 1
Get Updates
Available for Pickup
Text & Email Updates
Proof of Delivery
Tracking History
Product Information
See Less
Tracking Number: EJ699436413US
Scheduled Delivery by
Status
SATURDAY
Available for Pickup
9
by
October 12. 2021 at 9:07 am
OCTOBER
BROOKLYN NY 11232
2021 1
6:00pm
Get Updates
Available for Pickup
See More
Isabel Maxwell, Paralegal, Leah Saffian, Inc.
LAW OFFICES OF LEAH SAFFIAN; LEAH SAFFIAN BA JD LLM
11420 SANTA MONICA BLVD #25424 LOS ANGELES, CA 90025, US
NOTICE: The information transmitted by this email is intended only for the person or entity to which it is
addressed. This email may contain proprietary, business-confidential and/or legally privileged material. If
you are not the intended recipient of this message, be aware that any use, review, retransmission, distribution,
reproduction or any action taken in reliance upon this message is strictly prohibited. If you received this in
error, please contact the sender Isabel Maxwell at Te
and delete the material from all
computers.
EFTA00016261


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
Cc: Christian Everdell
"Mark S. Cohen"
)"
(USANYS)"
Subject: Re: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 17:08:37 +0000
Much appreciated.
Thank you-
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Dec 29, 2020, at 11:02 AM,
)
wrote:
Bobbi,
I hope you and your team are having a wonderful holiday season too, thanks.
I am reaching out to MDC legal counsel to discuss the issues you have raised in your email and will reach back out to you
after that conversation.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015899

=== Page 2 ===
From: BOBBI C STERNHEIM
Sent: Monday, December 28, 2020 8:42 PM
To:
Cc: Christian Everdell
>; Mark S. Cohen
Subject: Ghislaine Maxwell 02879-509
Good evening,
We hope you and your family had a joyful holiday.
In response to your 12/14 email, we are requesting that Ms. Maxwell be permitted to use the
laptop, in lieu of the MDC computer,, during the typical length of time other inmates are permitted
out of their cells (our understanding is 6 am - 9:30 pm daily, extended to 10:30 pm on weekends.)
The voluminous discovery is easier to access and review on the laptop. The MDC computer turns
off every two hours and is not capable of opening all documents, and volume of discovery
may be too taxing for the operating system.
We also want to bring to your attention some of the ongoing issues concerning Ms. Maxwell's
conditions and restrictions.
The constant rotation of security staff results in inconsistency of rules and restrictions, the current
shift being unnecessarily restrictive, punitive, and threatening.
Ms. Maxwell is ordered to remain in specific locations within her isolation cell
to accommodate capture on the handheld camera, restricting her use of an already small
confinement area.
Her use of the laptop has been restricted.
She is invasively surveilled while showering.
Her cell is cold and precipitation accumulates on the concrete block walls.
Over the holiday weekend, a third blanket, used by Ms. Maxwell to keep herself warm, was
removed leaving her cold; and she now has the onset of a cold.
The blanket was returned the next day, after complaint was made by counsel.
The open-mouth, wanding, pat-down, and in-and-behind ear searches continue,
with more frequently than other inmates are searched.
Her cell and legal papers are searched multiple times a day, a disruption to the organization of her
legal work and an invasion into her privileged work product.
She has not received daily newspapers for almost 3 weeks, and has not received certified mail
(return receipts indicating delivery to MDC on 12/17) and non-certified mail for more than a week.
We will keep you apprised of our concerns.
Your assistance is appreciated.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main:
Cell:
Fax:
EFTA00015900

=== Page 3 ===
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
EFTA00015901


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From:
To:
Subject: RE: call from Maxwell attorneys
Date: Tue, 21 Jan 2020 19:53:36 +0000
Chris and Mark just called me a few minutes ago, wanting to generally check in and see if we wanted or needed anything
from them. I said that as a general matter, in terms of status, the investigation is ongoing, and that I didn't have any
additional information beyond that. On whether we needed anything, I said I would circle up with the team and get them
an answer on that. Initially my thought was to say no, nothing needed from them right now, but now I wonder, do we
want to issue any document subpoenas to GM? Photos, communications, journals, memo pads, financial records
associated with Epstein, or anything else
thoughts??
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
MARTIN G. WEINBERG, P.C.
ATTORNEY AT LAW
EMAIL ADDRESSES:
BOSTON, MASSACHUSETTS 02116
FAX
NIGHT EMERGENCY
July 26, 2019
By Electronic Mail
Assistant United States Attorneys
U.S. Attorney's Office for the
Southern District of New York
New York, New York 10007
Re:
United States V. Jeffrey Epstein, No. 19-cr-00490
Defendant's First Request for Discovery
Dear
:
We represent Jeffrey Epstein in the above-referenced matter. We write to request the
preservation and production of several important categories of documents.
The following request and future requests¹ encompass not only documents and
information in your office's possession, custody, or control, but also documents that the
government has the legal right or practical ability to obtain. Such information includes, but is
not limited to, information in the possession, custody, and control of any agency of the United
States involved in any way in regulating or investigating the activities alleged in the Indictment
or related transactions, including but not limited to the Department of Justice (including but not
limited to the Child Exploitation and Obscenity Section, other offices of "Main Justice," the
Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and
Exchange Commission, and the Department of Homeland Security. In addition, such
information includes information in the possession, custody, and control of any local, state, or
I All of these requests are/will be continuing in nature, requiring supplementation in accordance with, inter alia,
Rule 16(c) of the Federal Rules of Criminal Procedure.
EFTA00016132

=== Page 2 ===
foreign law enforcement entities involved in any way in regulating or investigating the activities
alleged in the Indictment or related transactions.²
Whether or not you to intend to comply with this (or future) requests for discovery, we
respectfully request that you: (1) preserve all documents³, communications⁴ and/or tangible
objects related to, concerning, or otherwise referring to Mr. Epstein ("Responsive Material"); (2)
inform any and all entities described above, who you believe to have Responsive Material to
preserve it; and (3) inform defense counsel whether these entities intend to comply with this
request. In response to your email of today's date, we would specifically (and without waiving
the other requests contained herein) ask you communicate our preservation request to AUSAs
of the Northern District of Georgia, to CEOS and anyone
else at Main Justice that you have knowledge of as being involved in communications regarding
the NPA and the decision by the Southern District of New York to indict, and to any prosecutor
at either the Southern or Middle Districts of Florida (or anyone other than AUSA
at the Northern District of Georgia), with whom you have had any communication
regarding Mr. Epstein, the NPA, the receipt of evidence, or the decision by the Southern District
of New York to seek an indictment of Mr. Epstein. Our request that you preserve documents is
spelled out in this broader letter but certainly encompasses the Offices identified above. We
additionally request that the FBI agents working with any of these offices, or with the Southern
District of New York receive the same preservation request. The types of communications for
which we seek preservation (and ultimately production) are set forth below.
While Mr. Epstein intends to provide a more complete request for discovery in the
coming days, Mr. Epstein requests that the government expeditiously produce the following
categories of documents each of which are highly relevant to Mr. Epstein's forthcoming motion
to dismiss the Indictment as barred by the 2007 non-prosecution agreement between the
Department of Justice and Mr. Epstein (the "NPA"). Each is subject to disclosure pursuant to the
government's obligations under, inter alia, Brady V. Maryland, 373 U.S. 83 (1963) and the
Federal Rules of Criminal Procedure.
Mr. Epstein seeks all documents, communications, and/or tangible objects relating to,
concerning, or referring to:
1. Any investigatory files provided to the United States Attorney's Office for the Southern
District of New York (or FBI agents working therewith) by the United States Attorney's
2 Such entities include, but are not limited to, the New York Police Department, Manhattan District Attorney's
Office, State Attorney's Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County
Sheriff's Office, and New Mexico Attorney General's Office, which recently confirmed that it would be sharing
evidence with "New York prosecutors." See Patrick Hayes & Chris Ramirez, Balderas Believes Previous
Investigations Failed Epstein's Alleged NM Victims. (July 16, 2019), https://www.kob.com/new-mexico-
news/balderas-believes-previous-investigations-failed-epsteins-alleged-nm-victims/5425345/
3 The term "documents" should be construed broadly to include do any documents or electronically stored
information-including writings, drawings, graphs, charts, photographs, sound recordings, video recordings,
images, and other data or data compilations.
4 The term "communications" means the transmittal of information (in the form of facts, ideas, inquiries or
otherwise).
EFTA00016133

=== Page 3 ===
Offices for the Southern District of Florida, the Middle District of Florida, and/or the
Northern District of Georgia (or FBI agents working therewith);
2. Any investigatory files that were received or accessed by the United States Attorney's
Office for the Southern District of New York (or FBI agents working therewith) that were
sent or disclosed by or originated with the United States Attorney's Offices for the
Southern District of Florida, the Middle District of Florida, and/or the Northern District
of Georgia (or FBI agents working therewith);
3. Communications regarding Mr. Epstein between and among "Main Justice" (including
the Child Exploitation and Obscenity Section) and the United States Attorney's Offices
for the Southern District of Florida, Middle District of Florida, Northern District of
Georgia, and the Southern District of New York;
4. Any decision to initiate (or not initiate) criminal proceedings against Mr. Epstein;
5. The NPA, including but not limited to communications within the Department of Justice,
with counsel for Mr. Epstein, with representatives of the United States Attorney's offices
for the Southern and Middle District of Florida or the Northern District of Georgia and/or
counsel for the alleged victims;
6. Communications with alleged victims (or their counsel), including but not limited to
consultations conducted in relation to the government's response to the court's summary
judgment order and proposed remedies in Jane Doe V. United States, No. 08-cv-80736
(S.D. Fl.);
7. Information provided by alleged victims (or their counsel) related to Mr. Epstein prior to
the return of the above-captioned Indictment;
Please advise us whether the government will comply with the above requests SO that Mr.
Epstein can determine whether it will be necessary to seek judicial intervention. We are
available to discuss any of the foregoing requests with you when convenient. We reserve the
right to request further discovery and additional particulars as the case progresses.
Finally you have asked why we believe that these materials are necessary. In short, we
intend to file a future Motion to Dismiss based on the September 24, 2007 NPA, contending that
properly construed it constitutes a global resolution of Mr. Epstein's then-existing offense
conduct. Further, we believe that a production of the requested documents would reflect
communications between the various identified United States Attorney's Offices that would be
inconsistent with the duty to not circumvent or transfer a case from the immunizing district to
another district even if the NPA is ultimately determined to be venue specific. We also will
contend that the documented efforts of the Southern District of Florida, see Jane Doe V United
States Dkt 205-2, 08 cv 80736 and more recent interactions between the Northern District of
Georgia which stands in the shoes of the Southern District of Florida with victims and their
attorneys was inconsistent with the immunity-commitments that were incorporated into the NPA.
EFTA00016134

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We will be addressing all related topics in our future Motion to Dismiss and Motion for
Production of Documents relevant to the Motion to Dismiss.
Very truly yours,
Reid Weingarten
Martin G. Weinberg
Michael Miller
Martin G. Weinberg, P.C.
Steptoe & Johnson LLP
Boston, MA 02116
New York, NY 10036
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about Epstein
Date: Mon, 24 Aug 2020 16:23:09 +0000
Received, thanks.
From:
Sent: Monday, August 24, 2020 11:55 AM
To:
Cc:
Subject: RE: Civilian Crime Report from
suggesting a prisoner has info about Epstein
Sorry, this goes with that last one.
From:
Sent: Monday, August 24, 2020 11:49 AM
To:
Cc:
Subject: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about Epstein
Attached is a Civilian Crime Report for you to review. We sent our usual letter with the
form to be completed, but this particular submission does not really fit that so we might
not get anything more, but let us know if we do that you want to see it.
, please
make a note in the log. Thank you.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc: "Strauss, Audrey (USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: UMR
Date: Tue, 29 Jun 2021 17:15:09 +0000
Importance: Normal
Hi
Please transmit this UMR and copy those on this email on the confirmation. Thank you!
TO:
THE OFFICE OF THE ATTORNEY GENERAL
THE OFFICE OF THE DEPUTY ATTORNEY GENERAL
FROM:
UNITED STATES ATTORNEY
SOUTHERN DISTRICT OF NEW YORK
PHONE:
DISTRICT POC:
Audrey Strauss, U.S. Attorney
Phone:
SYNOPSIS:
In connection with USAO-SDNY's defense of the Bureau of Prisons ("BOP") in ongoing Freedom of Information Act
("FOIA") litigation against The New York Times, on Friday, July 2, 2021, the USAO-SDNY plans to release approximately
2,700 pages of BOP documents related to Jeffrey Epstein's incarceration and suicide at the Metropolitan Correctional
Center ("MCC"). These records were previously withheld due to the ongoing criminal prosecution against Tova Noel and
Michael Thomas for falsifying records on the night of Epstein's suicide. As noted in UMR #2021-05-66021, USAO-SDNY
entered into deferred prosecution agreements with Noel and Thomas in May 2021 and as such, USAO-SDNY no longer
plans to assert a FOIA exception related to that criminal prosecution. The BOP documents the USAO-SDNY plans to
release to The New York Times, which will be immediately available for publication by the Times, include: (i) internal BOP
memoranda describing the events and circumstances of Epstein's incarceration and suicide, including the numerous
failures that allowed Epstein the opportunity to kill himself; (ii) Epstein's psychological records from MCC; (iii) the autopsy
report prepared by the New York City Office of the Medical Examiner ("OCME"); and (iv) internal emails within BOP and
between BOP and USAO-SDNY from the day of Epstein's suicide reflecting generally a lack of understanding of what had
happened. USAO-SDNY has notified our counterparts at the BOP and DOJ-OIG about the pending release.
DESCRIPTION:
On August 10, 2019, inmate Jeffrey Epstein committed suicide while housed in the Special Housing Unit at the
MCC. USAO-SDNY is currently defending the BOP in connection with ongoing FOIA litigation filed by The New York Times
seeking documents regarding Epstein. Previously, BOP had withheld a number of documents based on the pendency of
the criminal prosecution of Tova Noel and Michael Thomas, the two guards on duty the night of Epstein's suicide who
EFTA00014902

=== Page 2 ===
were accused of falsely indicating on BOP forms that they had completed required institutional counts and rounds. As
noted in UMR # 2021-05-66021, in May 2021 USAO-SDNY entered into deferred prosecution agreements with Noel and
Thomas and as such, USAO-SDNY has notified the presiding Judge in the FOIA litigation that BOP no longer plans to assert
a FOIA exception related to that criminal prosecution. Accordingly, pursuant to Court-ordered deadlines in the FOIA
litigation, the USAO-SDNY must produce the previously-withheld documents, which number approximately 2,700 pages,
by July 2, 2021 to The New York Times, who will then be free to publish those materials.
The materials primarily consist of internal BOP memoranda, reports, emails, and documents, as well as emails with USAO-
SDNY, as well as the autopsy report prepared by OCME. As noted above, the documents include the following topics and
materials: (i) internal BOP memoranda from the day and night of Epstein's suicide; (ii) a photograph of a sign that was
hung in the Special Housing Unit that stated that rounds on Epstein were mandatory, signed "God," which had been
defaced to include a question mark after "mandatory"; (iii) Epstein's psychological records at MCC, which generally show
that he claimed not to be suicidal, attempted to manipulate staff, and received some special treatment at MCC; (iv)
internal BOP memoranda evaluating the circumstances and failures that led to the conditions in which Epstein could kill
himself, including the failure to reassign a cellmate, to perform counts or rounds, to ensure adequate staffing at MCC, and
other failures at the institution; (v) emails within BOP and between BOP and USAO-SDNY from the day of Epstein's suicide
which show efforts to find out what was happening at MCC and frustration that MCC was not providing information; (vi)
emails showing that Main Justice took an interest following Epstein's suicide, and sent individuals to tour MCC; and (vii)
the OCME autopsy report concluding that Epstein committed suicide by hanging. Pursuant to established case law, BOP
plans to redact photographs of Epstein's corpse and photographs from the autopsy, as well as the names of AUSAs and
lower-level BOP staff members. As noted above, USAO-SDNY has notified our counterparts at the BOP and DOJ-OIG
regarding this pending release.
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=== Page 1 ===
Event:
proffer (re abuse)
Start Date: 2019-12-04 19:00:00 +0000
End Date: 2019-12-04 22:00:00 +0000
Organizer:
Location: Winston & Strawn offices,
Class: X-PERSONAL
Date Created: 2019-12-03 01:24:24 +0000
Date Modified: 2019-12-03 01:24:24 +0000
Priority: 5
DTSTAMP: 2019-12-02 23:47:53 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
)"
Cc:
(USANYS)"
Subject: RE: NT 3500
Date: Sun, 11 Apr 2021 06:48:50 +0000
These are all set.
From:
)
Sent: Saturday, April 10, 2021 11:07 PM
To:
is
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: RE: NT 3500
Hi
Below are the changes that are needed for my section:
Please delete the following folders:
is the same person as
,
- would you please move everything from the
folder into the
folder?
Please merge everything in the
folder into the
folder
is the same persons as
,
who is a testifying witness. Would you please move the
entire
folder into the
oflder?
With those changes, my section (101 through 196) is ready to go.
Thanks so much,
From:
Sent: Saturday, April 10, 2021 12:33 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: NT 3500
Hi
EFTA00015833

=== Page 2 ===
Thanks for all your work on this project. I few things from my review, though I'll likely send some additional things
tomorrow:
The
folder contains just one report, and I think that goes in the
folder instead.
Please move it and delete his folder. Same thing for the
folder.
are the same person and the folders can be merged under the name
is the same person as
a potential testifying witness. Could you please move those
materials and delete the folder?
The stuff in the
folder should actually go in the
folder, and you can delete
the one for
once the stuff is moved over.
In the
folder, there's a transcript of a deposition of Mark Epstein. Could you please move that into a
new, NTW folder for him?
could you please
move these to the not-a-witness folder you created? We'll deal with the contents later, but not in the context of
the NTW production.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00015834


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=== Page 1 ===
From:
)"
To:
)"
)"
,
Subject: RE: Jury instructions letter
Date: Sun, 21 Nov 2021 00:11:04 +0000
Attachments: 2021-11-20_GM_edits_to_limiting_instructions_v3_
).docx
Here's mine. Thanks.
From:
)
Sent: Saturday, November 20, 2021 6:57 PM
To:
is
is
Subject: RE: Jury instructions letter
Thanks so much,
My thoughts and edits attached. This goes to
next, I think.
From:
Sent: Saturday, November 20, 2021 5:35 PM
To:
is
;
(
)
is
Subject: Jury instructions letter
Hey team,
Jury instructions letter attached. Comments welcome.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00014660


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell Link
Date: Mon, 29 Nov 2021 18:03:23 +0000
Thanks!
From:
Sent: Monday, November 29, 2021 12:53 PM
To:
Cc:
>;
Subject: Re: Maxwell Link
Sure thing. Looks like a 45 minute lunch break will start shortly. Swearing jury now.
Sent from my iPhone
On Nov 29, 2021, at 12:49 PM,
wrote:
That's good. McEnany also asked Wendy to work on this so maybe touch base with her too?
From:
Sent: Monday, November 29, 2021 12:48 PM
To:
is
Cc:
Subject: Fwd: Maxwell Link
If okay with you, l'll post an update to the VW page for openings today with the information about overflow courtrooms
and in bold "There will not be a public audio feed in this trial."
Sent from my iPhone
Begin forwarded message:
From: Joseph Pecorino
Date: November 29, 2021 at 12:19:43 PM EST
To:
Subject: FW: Maxwell Link
Hey Nick - Ed also sent something along.
From: Edward Friedland
Sent: Monday, November 29, 2021 12:01 PM
To:
EFTA00014905

=== Page 2 ===
Cc: Joseph Pecorino
>; Matthew Rogers
Subject: FW: Maxwell Link
This info on your web page is outdated and is causing the public to try and access the Maxwell matter by phone. Can
you pull down the access number info and update with the latest order which says in-person?
Edward A. Friedland, Esq.
District Court Executive
United States District Court
Southern District of New York
From: Joseph Pecorino
Sent: Monday, November 29, 2021 11:57 AM
To: Edward Friedland
Subject: Maxwell Link
https://www.justice.gov/usao-sdny/united-states-v-ghislaine-maxwel
Joseph Pecorino
Office of the District Executive
<image001.jpg>
United States District Court
Southern District of New York
Email:
Office:
PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS
MAIL
<mime-attachment>
EFTA00014906


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=== Page 1 ===
From: "
(USANYS)"
To: "
NYS) 4"
Subject: FW: Epstein
Date: Thu, 24 Jan 2019 14:20:27 +0000
Importance: Normal
Attachments: Letter_1.pdf
Not sure if this went through last night. Prepare to be disgusted.
From:
Sent: Wednesday, January 23, 2019 6:39 PM
To:
(USANYS)
Cc:
(USANYS)
is
is
(USANYS)
Subject: RE: Epstein
Yes, got 'em, but unfortunately most of the files are too big to send via email - l'll send an email to Lou asking for share
drive access for you both, and when you get access the defense letters we currently have are here (the smallest one is
attached):
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\Jeffre
Epstein\Letters from Epstein's attorneys
and the indictment materials we currently have, including draft indictments, are here:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\Jeffrey Epstein\
thanks,
Alex.
From:
(USANYS)
Sent: Wednesday, January 23, 2019 18:25
To:
)
is
)
>; ; Kurland,
Abigail (USANYS)
Cc:
(USANYS)
Subject: Epstein
Any progress in getting the scanned docs from the trip? Particularly interested in seeing the draft indictment and defense
submissions.
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
(USANYS)"
Subject: FW: 20-3061 United States of America V. Maxwell "Case FILED"
Date: Thu, 10 Sep 2020 18:11:22 +0000
We received this new appeal in a case of yours. Could you please file a notice of appearance as additional
counsel as soon as possible? Below is a link to the model:
<\\usa.doj.gov\district\NYS\StAndrews\Common\Fom Library\criminal\forms\Appeal\Notice of Appearance
for Substitute, Additional, or Amicus Counsel where WSS lead (model).pdf>
Thanks!
From: cmecf@ca2.uscourts.gov <cmecf@ca2.uscourts.gov>
Sent: Thursday, September 10, 2020 12:30 PM
To:
(USANYS)
Subject: 20-3061 United States of America V. Maxwell "Case FILED"
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was entered on 09/10/2020 at 12:28:44 PM EDT and filed on 09/09/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
NOTICE OF INTERLOCUTORY CRIMINAL APPEAL, with district court docket, on behalf of Appellant
Ghislaine Maxwell, FILED. [2927741] [20-3061]
Notice will be electronically mailed to:
-:
Laura Menninger, -:
, Assistant U.S. Attorney:
EFTA00016306

=== Page 2 ===
Notice will be stored in the notice cart for:
, -
The following document(s) are associated with this transaction:
Document Description: Criminal_Docketing_Notice
Original Filename:
/opt/ACECF/live/forms/
.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/09/2020] [FileNumber=2927741-1]
[19119a00cfb797cd385bf20b842a5d8817a455c1f242e760a4b5013e97ad8a65a4373fdba31682cba734d4789c1c7
3c863638ff8bec924a0574870ba27e66371]]
Recipients:
Laura Menninger, -
Assistant U.S. Attorney
Document Description: Case FILED
Original Filename: NOA 20-cr-330.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/09/2020] [FileNumber=2927741-0]
[aa9ef30deeb0f4a13306ea456f42c5d3d462cdcc8083557907cc8a9dba8e241d8426b8e7750a78f95340d2c896a4d
5b46c16001da2f3221d27bc37937b9ed0d5]]
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=== Page 1 ===
From: Nathan NYSD Chambers
To:
)"
,
)"
(USANYS)"
"
Jeff Pagliuca
"Laura
,
Menninger"
Subject: 20cr330, US V. Maxwell
Date: Wed, 24 Nov 2021 19:36:14 +0000
Attachments: 20cr330_Order_re_Protective_Order_11.24.21.pdf;
20cr330_Subpoena_Protective_Order_11.24.21.pdf
Counsel:
Attached please find two Orders issued by Judge Nathan, which will be docketed shortly.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00016470


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Fri, 21 Jun 2019 23:06:37 +0000
Importance: Normal
Attachments: Epstein_NPA,_dated_2007-09-24.pdf
No problem and definitely - NPA attached.
From:
Sent: Friday, June 21, 2019 19:06
To:
Subject: RE:
Thanks so much. I should have clarified that Geoff wanted to review them over the weekend. Could you please also send
me the Florida NPA? Thanks again.
From:
Sent: Friday, June 21, 2019 7:01 PM
To:
Subject: RE:
Hey sorry, didn't realize you needed them this afternoon. They're attached - initial email with the pros memo and the
decision. And let me know if anything else would be helpful, happy to send along whatever. Thanks again.
From:
Sent: Friday, June 21, 2019 18:56
To:
Subject:
Hey
Can you please shoot me those docs when you can? Thanks very much.
Best,
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 1 of 9
LAW OFFICE OF
MARC FERNICH
MARC FERNICH maf@fernichlaw.com
810 SEVENTH AVENUE, SUITE 620
ALSO ADMITTED IN MASSACHUSETTS
NEW YORK, NEW YORK 10019
212-446-2346
FAX: 212-459-2299
www.fernichlaw.com
July 16, 2019
BY ECF
Hon. Richard M. Berman
USDJ-SDNY
500 Pearl St.
New York, NY 10007
Re: US v. Epstein, 19 CR 490 (SDNY)
Dear Judge Berman:
In response to requests from the Court and certain arguments made
yesterday by the government, we write to supplement Jeffrey Epstein's
request for bail.
First, make no mistake about the crux of the government's
detention argument and its necessary implications. Stripped to its core,
the government's position - - as urged in its letters and echoed again
yesterday - distills to this: the nominally rebuttable remand
presumption (connected with 18 USC $ 1591 charges) 1 plus Mr.
1 To be clear, Epstein contends that § 1591 and the concomitant remand presumption
do not contemplate or cover the core conduct at issue here: performing sexual
EFTA00014482

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 2 of 9
Hon. Richard M. Berman
July 16, 2019
Page 2
Epstein's wealth creates an irrebuttable presumption whereby no
condition(s) can reasonably assure personal appearance or protect the
public. The Court should reject the government's misguided effort to
effectively create a per se rule.2 Indeed, for the government, there's
literally nothing a person of Epstein's means could say, do or pledge to
rebut the operative presumption and make himself eligible for release.
That cannot be the law. Such a construction turns the statute's
massages for money. See Fierro U. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3
(SDNY July 2, 2012) (holding that sex purchasers from minors fall outside $ 1591's
ambit).
2 E.g., 7/15/19 Tr. 11 ("even if the defense were able at some point to rebut the
presumption by providing some more information, there simply is no way that they
can meet the standard here"); 7/12/19 Ltr. 5 ("even assuming the defendant's assets
are presently in the United States, nothing would prevent the defendant from
transferring liquid assets out of the country quickly and in anticipation of flight or
relocation. The defendant is an incredibly sophisticated financial actor with decades
of experience in the industry and significant ties to financial institutions and actors
around the world. He could easily transfer funds and holdings on a moment's [notice]
to places where the [g]overnment would never find them so as to ensure he could live
comfortably while a fugitive."); id. ("even were the defendant to sacrifice literally all
of his current assets, there is every indication that he would immediately be able to
resume making tens of millions of dollars per year outside of the United States
[T]here would be little to stop the defendant from fleeing, transferring his unknown
assets abroad, and then continuing to earn his vast wealth from a computer
terminal beyond the reach of extradition.") (footnote omitted); id. 7 ("the notion that
any individual co-signer could meaningfully secure a bond for this defendant strains
credulity").
EFTA00014483

=== Page 3 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 3 of 9
Hon. Richard M. Berman
July 16, 2019
Page 3
plain text - expressly providing that the presumption is "[s]ubject to
rebuttal," and otherwise mandating bail on the "least restrictive"
conditions that reasonably assure the defendant's presence and
community safety - on its head. It defies legislative intent. It thwarts the
presumption of innocence. And it violates the Fifth, Sixth and Fourteenth
amendment rights to due process, counsel, a defense and equal
protection, not to mention the Eighth Amendment guarantee of bail - all
based on a suspect if not invidious classification. To be sure, wealthy
defendants do not deserve preferential treatment. But they certainly
shouldn't be singled out for worse treatment - in effect, categorically
disqualified from bail, at least in a presumption case - on the basis of
their net worth.
Second, it bears emphasis that the presumption is hardly an
insurmountable bar to release in a $ 1591 prosecution.3 To the contrary,
courts have determined that there are suitable conditions under which
3 E.g., US U. Brinson, No. 13-CR-04-GKF, 2013 WL 11305792 (N.D. Okla. Feb. 8,
2013); US U. Afyare, No. 3:10-cr-00260, 2011 WL 1397820 (M.D. Tenn. April 13, 2011);
US v. Gardner, 523 F. Supp. 2d 1025 (N.D. Cal. 2007).
EFTA00014484

=== Page 4 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 4 of 9
Hon. Richard M. Berman
July 16, 2019
Page 4
defendants accused of trafficking minors are bailed - notwithstanding
the remand presumption.
Third, as apparent from Mr. Epstein's initial financial disclosure,
Mr. Epstein's finances are fairly complex. It would be impossible for Mr.
Epstein - given, among other impediments, his detention, inability to
quickly access pertinent records, and inability to quickly make a precise
valuation of particular assets - to provide a sufficient financial statement
by the Court's 5pm deadline. Mr. Epstein certainly recognizes the Court's
request for further transparency and is committed to providing a
complete and accurate disclosure. Accordingly, we propose that the Court
preliminarily accept the initial disclosure proffered last Friday and, if
intending to grant bail, include a release condition directing Mr. Epstein
to tender a comprehensive forensic accounting of his finances as
expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent
Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has
agreed to conduct the forensic investigation and prepare a report rapidly.
As counsel said during the July 15 argument, Epstein will agree to any
EFTA00014485

=== Page 5 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 5 of 9
Hon. Richard M. Berman
July 16, 2019
Page 5
monetary condition - consistent with his Sixth Amendment need to
retain counsel and pay ordinary expenses, which, at the Court's
discretion, could be subject to supervision by a Court-appointed trustee -
that collateralizes his assets as a condition of release.
Fourth, to the extent the government complains Epstein lacks
meaningful domestic ties, we clarify and emphasize that his brother
Mark, a U.S. resident, stands prepared to co-sign and secure a release
bond in the full amount of his "own net worth,"4 which exceeds $100
million - tangible proof of his certainty that Epstein will appear as
necessary.
Fifth, in response to the Court's inquiry about Epstein's New
Mexico registration status, the state's Public Safety Department formally
advised in August 2010 that "you are not required to register with the
State of New Mexico for your 2008 Florida conviction of Procuring
Person Under 18 for Prostitution." Nonetheless, in an abundance of
caution and as an extra precaution, Epstein consistently notified the
4 7/12/19 Ltr. 6 (footnote omitted).
EFTA00014486

=== Page 6 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 6 of 9
Hon. Richard M. Berman
July 16, 2019
Page 6
appropriate New Mexico official, Detective Deborah Anaya, when he
spent any time at his ranch there. (The underlying documents are
available upon request.)
Sixth, though some studies may well indicate that sex offender
recidivism rates "actually go[] up at 15 years," as Your Honor suggested
from the bench,5 others reach the opposite conclusion. For example, a
respected study found that the relapse risk drops substantially the longer
a person remains sex-offense free in the community. 6 Another
determined that it's mistaken to think of anyone who's been offense-free
for 15 years as high-risk.7
Seventh, to the extent third-party counsel (Mr. Boies) speculated
that the alleged November 28 and December 3, 2018 payments8 were
5 7/15/19 Tr. 34.
6 Hanson et al., "High-Risk Sex Offenders May Not Be High Risk Forever," Journal
of
Interpersonal
Violence
(March
2014),
https://www.researchgate.net/publication/261069441_High-
Risk Sex Offenders May Not Be High Risk Forever.
7 Ira Mark & Tara Ellman, "Frightening and High': The Supreme Court's Crucial
Mistake About Sex Crime Statistics" (2015). Constitutional Commentary. 419.
https://scholarship.law.umn.edu/concomm/419.
8 7/12/19 Ltr. 11.
EFTA00014487

=== Page 7 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 7 of 9
Hon. Richard M. Berman
July 16, 2019
Page 7
made to "witnesses who were cooperating with us"9 in civil litigation, he
is wrong. As explained in Court, the recipients were "long-time [Epstein]
friends and employees" 10 - not putative victims - and they never
cooperated with Mr. Boies. To the contrary, each invoked the Fifth
Amendment and refused to testify when civilly deposed, respectively, in
prior New York federal and Florida state civil proceedings. Subject to the
protective orders in these proceedings, we would be pleased to provide
relevant deposition transcripts.
Eighth, as for the Austrian passport the government trumpets, it
expired 32 years ago. And the government offers nothing to suggest - and
certainly no evidence - that Epstein ever used it. In any case, Epstein -
an affluent member of the Jewish faith - acquired the passport in the
1980s, when hijackings were prevalent, in connection to Middle East
travel. The passport was for personal protection in the event of travel to
dangerous areas, only to be presented to potential kidnapers, hijackers
9 7/15/19 Tr. 70-71.
10 Ibid. 69.
EFTA00014488

=== Page 8 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 8 of 9
Hon. Richard M. Berman
July 16, 2019
Page 8
or terrorists should violent episodes occur.
Ninth, the Court is undoubtedly aware of the highly charged
context surrounding this prosecution. In November 2018, media reports
suggested that Epstein received a plea deal that amounted to a "slap on
the wrist." Putting aside the robust negotiations leading to the non-
prosecution agreement (NPA) and the prison sentence that Epstein
completed, there can be no dispute that certain witnesses through their
attorney representatives, 11 the media - e.g., The Miami Herald - and
the public were all clamoring for his re-prosecution, Epstein traveled
extensively over these eight months and invariably returned to the
United States. That inescapable reality emphatically proves he won't flee
and entitles him to release - on any and all conditions the Court deems
appropriate.
11 See, e.g., Doe U. US, CV 807-36 (SD Fla.).
EFTA00014489

=== Page 9 ===
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 9 of 9
Hon. Richard M. Berman
July 16, 2019
Page 9
We thank the Court for its consideration and would be pleased to
provide any additional information at Thursday's appearance.
Respectfully,
/s/
Marc Fernich
Martin Weintraub
Reid Weingarten
cc:
All Counsel (ECF)
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=== Page 1 ===
JANE DOE #12
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 18
7/4/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 20
7/10/04
Conspiracy to entice a minor to
engage in prostitution
Ct. 8
7/4/04 -
EPSTEIN
Enticement of a minor to engage in
7/19/04
prostitution
Ct. 20
7/4/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 21
7/16/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 57
7/4/04-
EPSTEIN
Recruiting, enticing, providing, or
7/19/04
obtaining a person, knowing that she
is a minor and will be caused to
engage in a commercial sex act
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 1
JANE DOE #12
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Exhibit A
EFTA00016528

=== Page 2 ===
CONFIDENTIAL/PRIVILEGED/SEALED
November 19, 2020
Dear Judge Nathan,
I respectfully submit this letter in support of Ghislaine Maxwell's bail application.
History
1.
2.
3.
4. The person described in the criminal charges is not the person we know. I have never
witnessed anything close to inappropriate with Ghislaine; quite to the contrary, the Ghislaine
I know is a wonderful and loving person.
5. Until the explosion of media interest that followed the arrest and subsequent death in
custody of Jeffrey Epstein in July thru August 2019,
Privacy
1 I Page
EFTA00016529

=== Page 3 ===
6.
7. I was, of course, aware of Ghislaine's previous relationship with Epstein, a person I have
never met nor had any communication. The media coverage of Epstein is very different
today than it was
8. The "reporting" of Ghislaine over the past year has exploded exponentially. From the
time of Epstein's arrest and death in custody in the summer of 2019 until Ghislaine's own
arrest in July of this year, huge and increasingly frightening levels of media interest meant
There are many examples of violence
whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and
the recent Judge Salas attack are terrifying.
Twitter comments have
been particularly galling,
There are many other
gross and disgusting posts like this on the web that a simple search will bring up. I have also
received threatening messages through social media, which I have reported and blocked.
It is hard to communicate in words the feeling of being stalked, spied upon and trapped by
constant, 24/7 media intrusion
At one point, The Sun even put a "bounty" on her head.
2 I Page
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=== Page 4 ===
Despite our best efforts, there have still been life altering consequences as a result of the
media's harassment.
There are other examples of painful and real loss like this due to the media's aggressive
treatment of those who simply know Ghislaine; the entire experience has been most
regrettable.
My support for her bail application
12. I believe that Ghislaine had nothing to do with Epstein's crimes. She has pleaded not
guilty and denied the criminal allegations against her, and I fully believe that it is her intent
and desire to remain in the U.S. to face the ensuing process and to clear her name.
Over the past few years she has had dozens of alternative places she could have gone, but she
did not want to be perceived as running or as having done something wrong. She was
adamant to not only stay in the United States to fight the smears against her, but to be within
driving distance of New York.
She was not hiding from the SDNY, but she left
Her arrest came as a shock.
13. I did not initially come forward as a co-signer of her first bail application for the reasons
stated above, trying to protect
from ferocious media aggression.
13.
I believe
wholeheartedly in Ghislaine's commitment to stand trial and not to seek to leave the
jurisdiction should her bail application be successful.
I pray for Ghislaine's safety. I am praying for justice. And I pray for her constitutionally
afforded due process.
With humility and deep compassion, I am also praying for Epstein's victims.
3 I Page
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=== Page 1 ===
From:
To:
Subject: to print
Date: Mon, 29 Jun 2020 13:55:53 +0000
Attachments: GM_Final.pdf; 2020.06.29_Presentation_Outline_(final).docx
Thank you!
EFTA00017709


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=== Page 1 ===
From:
To:
(USANYS)"
Subject: FW: Corruption, Epstein, and Ghislaine
Date: Mon, 06 Jul 2020 16:21:49 +0000
Attachments: BILL_O'CONNELLChildRapeVictim.pdf; EpsteinO'ConnellMaxwell7520.pdf
Inline-Images: ~WRD000.jpg
FYI
From:
Sent: Sunday, July 5, 2020 7:05 PM
To:
Cc:
Subject: Corruption, Epstein, and Ghislaine
Hi,
My name is
and I reside in NH. I have been reporting a group of wealthy real estate developers,
nightclub and restaurant owners, along with rogue police who cater to them, donate for them, and seemingly
offer private police services to them.
One of the MA troopers is the brother of the nightclub owners and he's close to pedophile wealthy developer
Wm. O'Connell. (arrested for statutory rape and cocaine trafficking)
I have come across new information which leads me to believe the above group is tied to Epstein, and even
Ghislaine, but definitely the million dollar homes where she lived and the LLC's connected to them.
I have attached these documents on both a Google doc and PDF file for your viewing.
I know this group, with the exception of the pedophile and nightclub owners, because I was married to one I
divorced over twenty years ago, I dated another, and socialized with them. I have been compiling their
corruption for over ten years and have received enormous amounts of abuse and crimes committed against me
for doing so, and LE hasn't done one thing to stop them.
But, I'm still here sending my reports on them, and they're still issuing threats. This pedophile's victim was killed
in a fiery crash one week before his trial was to begin, so he got off those charges. But the similarities between
both he and Epstein are astounding, but I'm sure they knew him. See attached,
Bill O'Connnell
Epstein-Ghislaine doc
https://docs.google.com/document/d/DILdQy9FMJFM_-qe-SyJ5vr4Yp8006sDgliOZ3zDwhc/edit?usp=sharing
EFTA00016198

=== Page 2 ===
Thank you,


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=== Page 1 ===
11/26/21, 6:55 PM
Mail
(NY) (FBI) - Outlook
CART Review
Tue 10/13/2020 1:49 PM
To:
>
Hey just tried your cell. Feel free to give me a call
On Oct 13, 2020 6:27 PM,
> wrote:
Hey
Just spoke to
regarding CART stuff.
Mind calling if you have a few?
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
EFTA00014979


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=== Page 1 ===
Sex Offender Details Page - NY DCJS
Page 1 of 13
Offender Details
Anyone who uses this information to injure, harass or commit a criminal act
against any person may be subject to criminal prosecution.
Domiciled
More Photos
Additional Offender Photos
Offender Id
33216
Race
White
Last Name
EPSTEIN
Ethnicity
Unknown
First Name
JEFFREY
Height
6' 00"
Middle Name
E
Weight
180
DOB
Hair
Gray
Sex
Male
Eyes
Blue
Risk Level
3
Corr. Lens
Designation
No Designation
Photo Date
April 27, 2018
Applies
Current Addresses
Type
RES (Primary)
County
Address
LITTLE ST JAMES
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33..6/27/2019
EFTA00014421

=== Page 2 ===
Sex Offender Details Page - NY DCJS
Page 2 of 13
B3
ST THOMAS, Virgin Islands 00802
Type
RES (Secondary)
County
Address
PALM BEACH, Florida 33480
Type
RES (Secondary)
Country
France
Address
PARIS
Type
RES (Secondary)
Country
France
Address
JEFFREY EPSTEIN
PARIS 75116
FRANCE
Type
RES (Secondary)
County
New York
Address
NEW YORK, New York 10021-4102
Type
RES (Secondary)
County
Address
STANLEY, New Mexico 87056
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33.6/27/2019
EFTA00014422

=== Page 3 ===
Sex Offender Details Page - NY DCJS
Page 3 of 13
Type
RES (Secondary)
County
Address
GREAT ST JAMES
ST THOMAS, Virgin Islands 00802
Type
EMP (Primary)
County
Address
B3
ST THOMAS, Virgin Islands 00802
Law Enforcement Agency Having Jurisdiction
i
Virgin Islands Dept of Justice - Sex Offender Registry
Current Conviction
Title
Section
OUT
000000000
Subsection
Class
000000
U
Category
Counts
F
1
Description
Non-NYS Felony Sex Offense
Date of Crime
July 23, 2006
Date Convicted
June 30, 2008
Victim Sex/Age
Female, 14 Years
Female, 16 Years
Female, Unknown
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33..6/27/2019
EFTA00014423

=== Page 4 ===
Sex Offender Details Page - NY DCJS
Page 4 of 13
Arresting Agency
Florida Dept of Law Enforcement - Sex Offender Registry
Offense Descriptions
Sexual Intercourse
Deviate Sexual Intercourse
Sexual Contact
Relationship to Victim
None Reported
Weapon Used
None Reported
Force Used
Detail unknown
Computer Used
None Reported
Pornography Involved
None Reported
Sentence
Probation: 6 Month(s) Term: Time Served Unspecified
Previous Conviction(s) Requiring Registration
i
None Reported
Supervising Agency Information
i
None Reported
Special Conditions of Supervision
i
None Reported
Maximum Expiration Date/Post Release Supervision Date of Sentence:
None Reported
Scars, Marks & Tattoos
None Reported
Additional Names/Aliases
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33..6/27/2019
EFTA00014424

=== Page 5 ===
Sex Offender Details Page - NY DCJS
Page 5 of 13
EPSTEIN, JEFFREY, EDWARD
Current Vehicles
Lic. Plate No.
State
Year
2008
Make/Model
Color
Lic. Plate No.
State
Virgin Islands
Year
2015
Make/Model General Motor Corp. Yukon.
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
2018
Make/Model
Color
Lic. Plate No.
State
Virgin Islands
Year
2015
Make/Model
Color
Lic. Plate No.
State
Florida
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33...6/27/2019
EFTA00014425

=== Page 6 ===
Sex Offender Details Page - NY DCJS
Page 6 of 13
Year
2019
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
Florida
Year
2019
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
New York
Year
2016
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
Florida
Year
2018
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
New York
Year
2007
Make/Model Gulf Stream Unknown
Color
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=3...6/27/2019.
EFTA00014426

=== Page 7 ===
Sex Offender Details Page - NY DCJS
Page 7 of 13
Lic. Plate No
State
Virgin Islands
Year
2011
Make/Model
Color
Lic. Plate No.
State
Florida
Year
2017
Make/Model Chevrolet Express
Color
Black
Lic. Plate No.
State
New York
Year
2017
Make/Model Bentley Mulsanne
Color
Lic. Plate No.
State
Virgin Islands
Year
1989
Make/Model
Color
Lic. Plate No
State
Florida
Year
2016
Make/Model Chevrolet Suburban
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33..6/27/2019
EFTA00014427

=== Page 8 ===
Sex Offender Details Page - NY DCJS
Page 8 of 13
Color
Black
Lic. Plate No.
State
New Mexico
Year
2012
Make/Model Cadillac Escalade
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
1989
Make/Model
Color
Lic. Plate No
State
New Mexico
Year
2012
Make/Model Cadillac Escalade
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
2015
Make/Model General Motor Corp. Denali
Color
Black
Lic. Plate No.
State
Virgin Islands
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33...6/27/2019.
EFTA00014428

=== Page 9 ===
Sex Offender Details Page - NY DCJS
Page 9 of 13
Year
2010
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
2013
Make/Model
Color
Lic. Plate No
State
New York
Year
2015
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
2015
Make/Model General Motor Corp. Yukon
Color
Black
Lic. Plate No.
State
New Mexico
Year
2015
Make/Model Chevrolet Suburban
Color
Black
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33...6/27/2019
EFTA00014429

=== Page 10 ===
Sex Offender Details Page - NY DCJS
Page 10 of 13
Lic. Plate No.
State
Virgin Islands
Year
2012
Make/Model
Color
Lic. Plate No.
State
New York
Year
1988
Make/Model
Color
Lic. Plate No.
State
Year
2001
Make/Model
Color
Lic. Plate No.
State
New Mexico
Year
2013
Make/Model Ford Expedition
Color
Black
Lic. Plate No
State
New Mexico
Year
2008
Make/Model Land Rover Range Rover
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33...6/27/2019.
EFTA00014430

=== Page 11 ===
Sex Offender Details Page - NY DCJS
Page 11 of 13
Color
Black
Lic. Plate No.
State
New Mexico
Year
2007
Make/Model Hummer Hummer II
Color
Black
Lic. Plate No.
State
New Mexico
Year
2002
Make/Model Mercedes-Benz 500 Series
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
2010
Make/Model Chevrolet Suburban
Color
Black
Lic. Plate No.
State
Virgin Islands
Year
1968
Make/Model
Color
Lic. Plate No
State
Virgin Islands
https://www.crininaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33...6/27/2019
EFTA00014431

=== Page 12 ===
Sex Offender Details Page - NY DCJS
Page 12 of 13
Year
2008
Make/Model
Color
Lic. Plate No.
State
Virgin Islands
Year
2006
Make/Model
Color
Lic. Plate No.
State
Virgin Islands
Year
2011
Make/Model
Color
Lic. Plate No.
State
Virgin Islands
Year
2011
Make/Model
Color
Lic. Plate No.
State
Virgin Islands
Year
1999
Make/Model
Color
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33..6/272019
EFTA00014432

=== Page 13 ===
Sex Offender Details Page - NY DCJS
Page 13 of 13
https://www.criminaljustice.ny.gov/SomsSUBDirectory/offenderDetails.jsp?offenderid=33.6/27/2019
EFTA00014433


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=== Page 1 ===
From:
)"
To: Gloria Allred
Subject: Re: August 19th
Date: Wed, 14 Aug 2019 03:35:01 +0000
Inline-Images: image001.png; image002.jpg
Yes- thanks!
Sent from my iPhone
On Aug 13, 2019, at 10:56 PM, Gloria Allred
wrote:
Perfect. I will call you then. Should I reach you at the
number?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
From:
Sent: Tuesday, August 13, 2019 7:37 PM
To: Gloria Allred
Cc:
is
Subject: Re: August 19th
Thanks- I'm free tomorrow at 12:30 EST/ 9:30 am PST if that works.
Sent from my iPhone
On Aug 13, 2019, at 7:11 PM, Gloria Allred
wrote:
Tomorrow morning pacific is fine. What is best for you and which number should I call?
Get Outlook for Android
On Tue, Aug 13, 2019 at 11:32 AM -0700,
)"
> wrote:
Hi Gloria,
EFTA00014357

=== Page 2 ===
Thanks for reaching out. Do you have time to discuss briefly either today or tomorrow?
Thanks,
From: Gloria Allred
Sent: Monday, August 12, 2019 10:36 PM
To:
>; Diane Aldrich
Cc:
is
Subject: RE: August 19th
Good news. Another one of my clients who is an Epstein victim has agreed to fly to New York to meet with you on
August 19 in the afternoon. Is that time period still available? If so what time would work for you? I do have her
driver's license and I know she would like to fly with me on the Delta flight that I am taking on Sunday from L.A. to
New York. If you will have time to meet with her your federal agent who handles travel may contact my assistant,
Diane, tomorrow to arrange the details of my client's trip.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
From:
Sent: Friday, August 9, 2019 8:22 AM
To: Gloria Allred
Cc:
is
Subject: RE: August 19th
Thanks for letting us know. We understand that coming forward is a difficult decision, and we respect that.
From: Gloria Allred
Sent: Friday, August 9, 2019 11:17 AM
To:
Cc:
is
Subject: RE: August 19th
Unfortunately, at this point, she has decided that she does not wish to meet with you. I will let you know if she
changes her mind. Thank you for having followed up on this matter.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
EFTA00014358

=== Page 3 ===
www.amglaw.com
www.gloriaallred.com
<image005.png>
<image006.jpg>
From:
Sent: Friday, August 9, 2019 8:10 AM
To: Gloria Allred
Cc:
i
Subject: August 19th
Hi Gloria,
Hop you're doing well. I wanted to follow up on scheduling to see if August 19th at 2 p.m. still works to meet with
you and your client at our office. We're happy to be flexible on timing if you need to make other arrangements.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING
THE SENDER NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING
THE SENDER NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00014359

=== Page 4 ===
Martindale-Hubbell"
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2017
ALLRED, MAROKO & GOLDBERG
2018
Best Lawyers


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=== Page 1 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833(PAE)
V.
FEDERAL BUREAU OF PRISONS,
Defendant.
SUPPLEMENTAL DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
1.
I am Counsel to the Acting United States Attorney for the Southern District of
New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details
my service in this capacity and prior service in the USAO-SDNY. As noted therein, I am familiar
with the Freedom of Information Act requests filed by the New York Times Company (the
"FOIA Requests") that are the subject of this case, which seek records related to the
incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also
familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has
withheld in whole or in part pursuant to various FOIA exemptions, including BOP's
withholdings from the records provided back to BOP by the Office of the Inspector General of
the Department of Justice ("OIG") since the submission of my August 5, 2020, declaration.
2.
The statements contained in this declaration are based on my personal
knowledge, documents maintained in the files of the USAO-SDNY, conversations with members
of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and
conclusions made in accordance therewith.
1
EFTA00015517

=== Page 2 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 2 of 7
3.
I submit this declaration in further support of BOP's motion for summary
judgment in this case. Specifically, this declaration addresses the bases for the withholding in
whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption
7(A).
Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on
Account of Likely Interference with Noel
4.
5 U.S.C. § 522 (b)(7)(A) ("Exemption 7(A)") exempts from disclosure "records
or information compiled for law enforcement purposes, but only to the extent that the production
of such law enforcement records or information
could reasonably be expected to interfere
with enforcement proceedings
"
5.
I and the prosecutors responsible for the Noel prosecution have reviewed each of
the records provided back to BOP by OIG that BOP withheld in full or in part under Exemption
7(A) (the "7(A) Returned Records"), including those reflected as withheld in full at Entries 55-
57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson
(the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents
related to counts of inmates, staffing records, psychology records, and entries on certain BOP
logs for August 9 and 10, 2019. Each of these categories fall within the scope of Exemption
7(A).
6.
Public disclosure of the 7(A) Returned Records could reasonably be expected to
interfere with the pending Noel prosecutions. These records include information about which
numerous witnesses are expected to testify at trial, details that are not publicly known or known
to other witnesses, and information and documents prepared by potential trial witnesses. These
records also include potential trial exhibits, which some or all potential trial witnesses have not
seen. Premature disclosure of these records and/or the information contained therein could
2
EFTA00015518

=== Page 3 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 3 of 7
reasonably be expected to influence witnesses' potential testimony at trial and/or enable
witnesses to alter or shape their testimony to conform to other evidence.
7.
Further, premature public disclosure of any of the 7(A) Returned Records could
reasonably be expected to impair the government's (and the defendants') ability to seat a fair and
impartial jury in Noel. The government anticipates that some of these records will be entered
into evidence as exhibits at trial, and other records that may not be trial exhibits bear on the
contents of potential trial exhibits. Premature disclosure of these records and/or the information
contained therein could influence potential jurors' understanding of the evidence at trial and the
case overall. Similarly, premature disclosure of the records and/or the information contained
therein could prejudice potential jurors for or against the defendants in the Noel action, which
would also impair the government's (and the defendants') ability to seat a fair and impartial jury.
In addition, as noted above, these records include specific information about which witnesses are
expected to testify at trial, as well as information and documents prepared by potential trial
witnesses, such that premature public disclosure could reasonably be expected to influence
potential jurors' perception of the witnesses and the evidence to be presented at trial.
8.
The risks of interference with the Noel proceedings are heightened by the media
coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of
Epstein's death are unfounded. Premature release of the withheld records, particularly if the
records are released in part or without full context, may influence the perception of jurors who
have been exposed to such media coverage of speculation and theories.
9.
The considerations discussed above apply to each of the categories of 7(A)
Returned Records.
10.
First, as discussed in my prior declaration, the government anticipates that
documents related to counts of inmates, including count slips, associated inmate rosters, and
3
EFTA00015519

=== Page 4 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 4 of 7
records of rounds and checks, for dates between and including July 23, 2019, and August 12,
2019, will be the subject of trial testimony at the Noel trial. 7(A) Returned Records containing
such documents are noted at Entry 55 of the updated BOP index. In addition, the government
anticipates that some of these documents will be trial exhibits. Releasing these materials
prematurely could reasonably be expected to influence witnesses' potential testimony at trial,
allow witnesses to alter or shape their testimony to conform to other evidence, identify potential
government witnesses at the Noel trial, and/or influence potential jurors' perceptions of witness
testimony or evidence.
11.
One subcategory of these documents are records from the Special Housing Unit
(the "SHU"), specifically rosters of inmates in the SHU on August 9 and 10, 2019, and SHU
records showing which BOP employees conducted rounds in the SHU. Although BOP had
previously withheld six pages of these records in full, included at Entries 22, 34 and 37 of the
prior index submitted by BOP, the prosecutors responsible for the Noel prosecution and I
determined that these records could be released in part without interfering with the Noel
prosecution, provided that information on these records showing details of the occupants of the
SHU on August 9 and 10, 2019, and which BOP employees conducted rounds in the SHU was
redacted. Releasing such information prematurely could reasonably be expected to influence
witnesses' potential testimony at trial, allow witnesses to alter or shape their testimony to
1
In reviewing the records returned to BOP by OIG, the prosecutors responsible for the Noel and
Tartaglione prosecutions and I determined that a one-page attorney visit room inventory log,
dated July 21, 2019, and an 18-page inmate census roster, dated August 9, 2019, each of which
BOP had previously withheld in full under Exemption 7(A), could be released without a
reasonable expectation of interference with the Noel or Tartaglione prosecutions. The attorney
visit room inventory log was previously listed at Entry 26 of BOP's index, and the census roster
was previously included among the count documents noted at Entry 24 of BOP's index.
4
EFTA00015520

=== Page 5 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 5 of 7
conform to other evidence, identify potential government witnesses at the Noel trial, and/or
influence potential jurors' perceptions of witness testimony or evidence.
12.
Second, as discussed in my prior declaration, the government anticipates that
MCC staffing records, including daily assignment rosters for the MCC on July 23, August 9, and
10, 2019, will be the subject of witness testimony at the Noel trial. 7(A) Returned Records
containing such documents are noted at Entry 56 of the updated BOP index. 2 In addition, the
government anticipates that some of these documents will be trial exhibits. Releasing these
materials prematurely could reasonably be expected to influence witnesses' potential testimony
at trial, allow witnesses to alter or shape their testimony to conform to other evidence, and/or
influence potential jurors' perceptions of witness testimony or evidence.
13.
Third, as discussed in my prior declaration, the government anticipates that
certain psychological notes and records of Epstein prepared by BOP may be trial exhibits, the
subject of witness testimony, and/or were prepared by witnesses who will testify at trial. 7(A)
Returned Records containing such documents are noted at Entry 57 of the updated BOP index.
Premature disclosure of these records could influence the testimony of potential witnesses,
including by potentially causing them to alter or shape their testimony to conform to other
evidence. In addition, premature disclosure of these records could reasonably be expected to
prejudice potential jurors for or against the defendants in the Noel action, which would impair
the government's (and the defendants') ability to seat a fair and impartial jury.
14.
Fourth, as discussed in my prior declaration, the government anticipates that
entries in certain BOP logs for August 9 and 10, 2019, may be trial exhibits, the subject of
2 The daily assignment rosters included in the 7(A) Returned Records appear identical to the
daily assignment rosters BOP previously located and withheld in response to the FOIA Requests,
except that they contain a different date stamp, which I understand to indicate when they were
electronically generated.
5
EFTA00015521

=== Page 6 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 6 of 7
witness testimony, and/or were prepared by witnesses who will testify at trial. 7(A) Returned
Records containing such documents are noted at Entry 60 of the updated BOP index. Premature
disclosure of these materials could reasonably be expected to influence witnesses' potential
testimony at trial, allow witnesses to alter their testimony to conform to other evidence, and/or
influence potential jurors' perceptions of witness testimony or evidence.
7(A) Returned Records Withheld in Part from Disclosure Pursuant to Exemption 7(A) on
Account of Likely Interference with Tartaglione
15.
The release of portions of two 7(A) Returned Records could also be reasonably
expected to interfere with the Tartaglione prosecution. First, portions of psychological records,
withheld in full as noted at Entry 57 of the updated BOP index, concerning the circumstances of
Epstein's apparent suicide attempt on July 23, 2019, could reasonably be expected to interfere
with the prosecution of Tartaglione. Second, premature release of one of the entries in a
lieutenant's log dated July 23, 2019, concerning the circumstances of Epstein's apparent suicide
attempt on that date, could reasonably be expected to interfere with the prosecution of
Tartaglione.
16.
As discussed in my prior declaration, Tartaglione's interactions with Epstein in
July 2019 have been placed at issue by Tartaglione's defense counsel, specifically in connection
with the potential penalty phase of the case against Tartaglione. See Letter dated January 13,
2010, Dkt. No. 186, United States V. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January
21, 2020, Dkt. No. 193, United States V. Tartaglione, No. 16 Cr. 832 (KMK). In light of defense
counsel's position, the information contained in the psychological records and in the entry in the
lieutenant's log may be relevant evidence in any possible penalty phase of the case against
Tartaglione. In that event, premature release of the information could reasonably be expected to
6
EFTA00015522

=== Page 7 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 7 of 7
adversely affect the Tartaglione proceedings and influence potential jurors' perceptions of
Tartaglione, thereby impairing the district court's ability to seat a fair and impartial jury.
Segregability
17.
The 7(A) Returned Records withheld in full are exempt from disclosure in their
entirety under Exemption 7(A). To the extent the records contain any non-exempt information,
such information is inextricably intertwined with information that could reasonably be expected
to interfere with the Noel prosecution for the reasons discussed above. As noted in my previous
declaration, the media coverage of speculation and theories about Epstein's death makes the
segregation of any possibly non-exempt information particularly difficult because providing
information pertaining to Epstein without complete context risks contributing to the
dissemination of speculation and theories about his death. This, in turn, could reasonably be
expected to interfere with the district court's ability to seat a fair and impartial jury in Noel, for
the reasons discussed above.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Executed this 15 day of January 2021.
Russell 6m
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern District of New York
7
EFTA00015523


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c6: pdf
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=== Page 1 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Confidential
Page 1 of 7
FINANCIAL TRUST COMPANY, INC.
Asset Account Portfolio
October 1 - October 31, 1999
Gift Processing
Table of Contents
The holiday season will soon be here. If you
Page
plan to make securities gifts this year,
Portfolio Summary
2
please notify us before December 1, 1999.
Cash and Short Term
3
This will provide us with sufficient time to
Trade Activity
4
process your request and meet the
Account Transactions
5
year-end deadline.
Account Officers
Service Specialist: SCOTT/DENCKER
FINANCIAL TRUST COMPANY, INC.
C/O AMERICAN YACHT HARBOR
6100 RED HOOK, QUARTERS #2
ST THOMAS US VIRGIN ISLDS 00802
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036863
Chase
EFTA00015176

=== Page 2 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Asset Account Portfolio
Page 2 of 7
FINANCIAL TRUST COMPANY, INC.
October 01, 1999 - October 31, 1999
Overview
Market Value USD
Tax
Estimated Annual
Yield
Portfolio Summary
Oct 31
Cost USD
Income USD
%
Cash & Short Term
6,700,000.00
6,700,000.00
361,800.00
5.4
Total
6,700,000.00
6,700,000.00
361,800.00
5.4
Accrued Income
75,196.71
Total Portfolio Value
6,775,196.71
Asset Allocation
100% Cash and Short Term
EUR Conversion Rates
as of January 1, 1999
Currency
Exchange Rate
AST
13.7603
BEF
40.3399
DEM
1.9558
ESP
166.386
FIM
5.9457
FRF
6.5596
IEP
0.7875
ITL
1,936.2700
LUF
40.3399
NLG
2.2037
PTE
200.4820
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036864
Chase
EFTA00015177

=== Page 3 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Asset Account Portfolio
Page 3 of 7
FINANCIAL TRUST COMPANY, INC.
October 01, 1999 - October 31, 1999
Cash and Short Term
Summary by Maturity
Current Market Value
Estimated Annual Income
USD
USD
Less Than 3 Months
6,700,000.00
361,800.00
Total
6,700,000.00
361,800.00
Current yield is displayed for instruments with no maturity and YTM on market is displayed for instruments that mature.
Cash and Short Term by Type
Unit Cost
Tax Cost
Current
Estimated
Current
Description
Adjusted
Market
Adjusted
Market Value USD
Unrealized
Annual
Yield/
Cusip/S&P/Moody's Rating
Currency
Quantity
Original
Price
Original
Accrued Interest USD
Gain/Loss USD
Income USD
YTM %
Short Term by Maturity
JP MORGAN INSTITUTIONAL PRIME MONEY
USD
6,700,000
1.00
1.00
6,700,000.00
6,700,000.00
361,800.00
5.40
MARKET FUND
75,196.71
7-Day Annualized Yield: 5.34%
616918-20-7
Total Cash and Short Term
6,700,000.00
6,700,000.00
0.00
361,800.00
5.40
75,196.71
Important Information about Pricing and Valuations
Prices, some of which are provided by pricing services or other sources which we deem reliable are not guaranteed for accuracy or as realizable values
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036865
Chase
EFTA00015178

=== Page 4 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Asset Account Portfolio
Page 4 of 7
FINANCIAL TRUST COMPANY, INC.
October 01, 1999 - October 31, 1999
Trade Activity
Realized Gain/Loss Summary
Amount USD
Short Term Gain/Loss
0.00
Long Term Gain/Loss
0.00
Note: S indicates Short Term Realized Gain/Loss
L indicates Long Term Realized Gain/Loss
Trade Activity by Type
Trade
Settlement
Realized
Date
Date
Type
Description
Currency
Quantity
Price/Unit
Market Cost/Proceeds
Tax Cost
Gain/Loss USD
Settled
Oct 1
Oct 1
Purchase
JP MORGAN INSTITUTIONAL PRIME MONEY
USD
20,000,000
1.00 20,000,000.00
MARKET FUND
Oct 4 Oct 4
Purchase
JP MORGAN INSTITUTIONAL PRIME MONEY
USD
5,000,000
1.00 - 5,000,000.00
MARKET FUND
Oct 19 Oct 19 Sale
JP MORGAN INSTITUTIONAL PRIME MONEY
USD
- 18,300,000
1.00 18,300,000.00 - 18,300,000.00
MARKET FUND
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036866
Chase
EFTA00015179

=== Page 5 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Asset Account Portfolio
Page 5 of 7
FINANCIAL TRUST COMPANY, INC.
October 01, 1999 - October 31, 1999
Account Transactions
Cash Activity Summary
Amount this
Amount Year
Period USD
to Date USD*
Beginning Balance
.00
Credits
Sales, Maturities, Redemptions
18,300,000.00
18,300,000.00
Miscellaneous Receipts
25,000,000.00
25,000,000.00
Debits
Purchases of Securities
- 25,000,000.00
- 25,000,000.00
Miscellaneous Disbursements
- 18,300,000.00
- 18,300,000.00
Ending Balance
.00
*Year to date information is calculated on a calendar year basis.
Activity by Date
Settlement
Date
Type
Quantity Description
Amount USD
Oct 1
Purchase
20,000,000 JP MORGAN INSTITUTIONAL PRIME MONEY
20,000,000.00
MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/01/99
Oct 1
Misc. Receipt
FUNDS TRANSFERRED TO BRKRG
20,000,000.00
AC# Q78805001 (PRN) FROM
BRKRG AC# Q78859008 (PRN)
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036867
Chase
EFTA00015180

=== Page 6 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Asset Account Portfolio
Page 6 of 7
FINANCIAL TRUST COMPANY, INC.
October 01, 1999 - October 31, 1999
Activity by Date
continued
Settlement
Date
Type
Quantity Description
Amount USD
Oct 4
Purchase
5,000,000 JP MORGAN INSTITUTIONAL PRIME MONEY
- 5,000,000.00
MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/04/99
Oct 4
Misc. Receipt
FUNDS TRANSFERRED TO BRKRG
5,000,000.00
AC# Q78805001 (PRN) FROM
BRKRG AC# Q78859008 (PRN)
Oct 19
Sale
- 18,300,000 JP MORGAN INSTITUTIONAL PRIME MONEY
18,300,000.00
MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/19/99
Oct 19
Misc. Disbursement
TRANSFERRED BY WIRE TO
- 18,300,000.00
BEAR STEARNS
FAO GHISLAINE MAXWELL
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036868
Chase
EFTA00015181

=== Page 7 ===
10
Morgan Guaranty Trust Company of New York
1999
345 Park Avenue, New York, NY 10154-1002
JPMorgan
Account Number: Q 78805-00-1
Asset Account Portfolio
Page 7 of 7
FINANCIAL TRUST COMPANY, INC.
October 01, 1999 - October 31, 1999
in Case of Errors or Questions About Your Electronic Transfers.
Telephone us at 1 (800) 576-6221 or write us at 500 Stanton Christiana Road, 1/OPS Newark DE 19713-2107 as soon as you can, if you think your statement is wrong or if you need more information about a transfer on the statement
We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared (1) Tell us your name and account number (2) Describe the error or the transfer you are unsure about and
explain as clearly as you can why you believe it is in error or why you need more information (3) tell us the dollar amount of the suspected error If you contact us orally, you must send us your complaint or question in writing
within 10 business days in order to preserve your rights We will investigate your complaint and will correct any error promptly If we take more than 10 business days to do this (20 days for purchases using VISA Check Card or for
international transactions). we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation
in case of errors or questions about your statement, including your line of credit.
If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction you must write to us on a separate sheet describing the error and send it to: J.P. Morgan,
Private Client Services, 345 Park Avenue, New York NY 10154-1002 We must hear from you no later than 60 days after the statement on which the error or problem appeared is sent You can telephone us at 1-800-576-6221 but doing so will not
preserve your rights.
in your letter, please provide the following information: (1) your name and account number; (2) the dollar amount of the suspected error; and (3) @ description of the error and explanation if you can, why you believe there is an error. If you need
more information you must describe the item you are unsure about
The J.P. Morgan Funds or The J.P. Morgan Institutional Funds or The American Century Funds
The J.P. Morgan, J.P. Morgan Institutional, and American Century mutual funds are distributed by Funds Distributor, Inc. J.P. Morgan Investment Management Inc. and American Century Investment Management serve as investment advisors to their respective fund families
Shares of the funds are not bank deposits and are not guaranteed by any bank government entity, or the FDIC Return and share price will fluctuate and redemption value may be more or less than originalcost While the money market funds seek to maintain a stable net asset
valueof $1.00 per share there is no assurance that they will continue to do so. The estimated annual income and dividend yield figures for mutual funds represent the funds' most recent income dividend annualized
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00036869
Chase
EFTA00015182


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=== Page 1 ===
From:
To:
Subject: Accepted:
proffer (re abuse)
Date: Wed, 04 Dec 2019 17:27:32 +0000
Importance: Normal
Attachments: unnamed
EFTA00016928


c1: EFTA00015339
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re:
Date: Thu, 12 Sep 2019 11:58:27 +0000
Correct. Thanks for checking in.
On Sep 12, 2019, at 7:57 AM,
(USANYS)
wrote:
See below from
lattorney. Is it fair to say that, at this time, the government is not
interested in further interviewing him on the Epstein matter?
Assistant United States Attorney
Southern District of New York
Sent from my iPhone
Begin forwarded message:
From: "
Date: September 12, 2019 at 7:32:55 AM EDT
To:
(USANYS)"
Subject: Re:
I'm going to visit
today. Please let me know if the Government is still interested in interviewing
him regarding the Epstein matter.
Law Offices of Javier A. Solano, PLLC
EFTA00015339

=== Page 2 ===
The Hub
On Sep 3, 2019, at 6:42 PM,
(USANYS)
wrote:
There is an ICE detainer.
From:
Sent: Tuesday, September 3, 2019 6:34 PM
To:
Subject: Re
Great. Let me know as soon as you find out.
Law Offices of Javier A. Solano, PLLC
On Sep 3, 2019, at 6:05 PM,
(USANYS)
wrote:
l'll check with the agents now.
From:
Sent: Tuesday, September 3, 2019 6:01 PM
To:
Subject: Re: Santos Felix
Do you happen to know if Santos still has an immigration hold? He believes that the hold was lifted. If it's not lifted
then there's no reason to even consider a bail application.
Law Offices of Javier A. Solano, PLLC
EFTA00015340

=== Page 3 ===
On Aug 29, 2019, at 7:32 AM,
(USANYS) <
wrote:
Great. Let's do 2:00 p.m. on Tuesday, September 3. We'll have
brought to our office. The
prosecutors handling the proffer will be
and
From:
Sent: Wednesday, August 28, 2019 10:59 PM
To:
(USANYS)
Subject: Re: Santos Felix
Let's do Tuesday afternoon.
Law Offices of Javier A. Solano, PLLC
EFTA00015341

=== Page 4 ===
On Aug 27, 2019, at 4:45 PM,
(USANYS) <
wrote:
No worries. Can you do next week on Tuesday afternoon or Thursday morning?
From:
Sent: Tuesday, August 27, 2019 4:40 PM
To:
(USANYS)
Cd
Subject: Re:
The jury went overnight again so unfortunately I will not be available tomorrow. We have to reschedule the
proffer.
My sincere apologies.
Law Offices of Javier A. Solano, PLLC
On Aug 27, 2019, at 9:43 AM,
wrote:
EFTA00015342

=== Page 5 ===
We summed up on Monday and I was expecting a verdict yesterday but the jury is still deliberating. I hope
and expect y
to get a verdict today, but I will let you know for sure at the end of the day.
Thanks,
Law Offices of Javier A. Solano, PLLC
On Aug 26, 2019, at 12:04 PM, E
(USANYS)
wrote:
Hello,
Are we confirmed for a proffer session with Mr.
on Wednesday, August 28, at 12:00? We can do
the proffer session at our office.
Best Regards,
Assistant United States Attorney
EFTA00015343

=== Page 6 ===
United States Attorney's Office
Southern District of New York
EFTA00015344


c1: EFTA00016769
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c3: VOL00008
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
REPLY MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER RENEWED MOTION FOR BAIL
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone:
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone:
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone:
Attorneys for Ghislaine Maxwell
EFTA00016769

=== Page 2 ===
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT
1
ARGUMENT
2
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
2
II.
The Government Has Not Carried Its Burden
4
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse
4
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All
of Her and Her Spouse's Assets in Support of Her Bond
5
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
7
D.
Extradition from France or the United Kingdom Is Highly Unlikely
8
E.
The Recent COVID Surge at MDC Further Justifies Bail
10
CONCLUSION
10
i
EFTA00016770

=== Page 3 ===
TABLE OF AUTHORITIES
Page(s)
Cases
United States V. Chen,
820 F. Supp. 1205 (N.D. Cal. 1992)
10
United States V. Orta,
760 F.2d 887 (8th Cir. 1985)
1
EFTA00016771

=== Page 4 ===
TABLE OF EXHIBITS
Exhibit A.
Julié Addendum Opinion (France)
Exhibit B.
Perry Addendum Opinion (U.K.)
EFTA00016772

=== Page 5 ===
PRELIMINARY STATEMENT
The only issue before the Court is whether conditions exist that can reasonably assure
Ms. Maxwell's appearance during this case. On this renewed application, Ms. Maxwell has put
before the Court a significant bail package, supported by detailed submissions, which warrant
her release on strict conditions. She and her spouse have committed to signing a bond in the full
amount of their net worth, regardless of the ownership of the underlying assets. She has
proffered seven additional sureties, consisting of her family and close friends, many of whom are
U.S. citizens and long-time residents, who have come forward at great personal risk and have
pledged meaningful assets. The government does not challenge the good faith and bona fides of
these proposed sureties. She has provided a detailed report from a respected accounting firm,
which was further reviewed by a former IRS special agent, setting forth a statement of her
financial condition, supported by voluminous documentation. The government does not
challenge the report's findings, nor its underlying documentation. She has agreed, in writing, to
give up any right she has or could have to contest extradition and submit to all other standard
travel restrictions. And she has noted that a key representation made by the government at the
initial bail hearing as to the strength of its evidence is simply not accurate -
,
and there is no "significant contemporaneous documentary
evidence" that corroborates its case.
With regard to any other defendant, this record would readily support release on strict
bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute
for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the
significant additional evidence proffered to the Court and further argues that a defendant cannot
be eligible for bail (apparently on any conditions), unless she can provide an absolute guarantee
against all risks. But this is not the legal standard. United States V. Orta, 760 F.2d 887, 888 n.4,
EFTA00016773

=== Page 6 ===
892-93 (8th Cir. 1985) ("The legal standard required by the [Bail Reform] Act is one of reasonable
assurances, not absolute guarantees."). Under, the Bail Reform Act, a defendant must be released
unless there are "no conditions" that would reasonably assure her presence. Here, the proposed
package satisfies the actual governing standard, and the Court should grant bail.
ARGUMENT
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
In evaluating the strength of the government's case in its prior ruling, the Court relied on
the government's proffer that the testimony of the three accusers would be corroborated by
"significant contemporaneous documentary evidence." (Tr. 82 (emphasis added)). The
government now expressly retreats from this position. It is abundantly clear from the
government's response that it has no "significant contemporaneous documentary evidence"-in
fact, it has virtually no documentary corroboration at all-and that its case against Ms. Maxwell
is based almost exclusively on the recollections of the three accusers, who remain unidentified,
concerning events that took place over 25 years ago. Moreover, the government offers no
specificity about when within the four-year period of the charged conspiracy the alleged
incidents of abuse took place. This, alone, is grounds for the Court to reconsider its prior ruling.
The few examples of documentary corroboration referenced by the government-which
are the same examples that the government touted at the initial bail hearing-pertain to Epstein,
not Ms. Maxwell. The government concedes that
(Gov. Mem. at 11 (emphasis added)). The
government further states that
" (Id.
(emphasis added)). The strength of the government's case against Jeffrey Epstein is not at issue
2
EFTA00016774

=== Page 7 ===
here. Whether or not the accusers' recollections as to Epstein are corroborated is irrelevant to
the strength of the evidence against Ms. Maxwell.
The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal
value. The government references t
(Id. at 11). But even the government concedes that, at best,
It is clear that the only evidence that Ms. Maxwell allegedly "groomed" the accusers or
knowingly facilitated or participated in Epstein's sexual abuse of minors will come solely from
the testimony of the three accusers. The government's case against Ms. Maxwell therefore rests
entirely on the credibility and reliability of these three witnesses. 2 Moreover, the substantive
counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1.
It is also telling that the government does not even attempt to rebut the defense's assertion that it
did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death
of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact
I The government also proffers that they will have "additional witnesses." (Gov. Mem. at 11). But these are not
"outcry" witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers.
Instead, they will testify only that "both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims
when those victims were minors." (Id.). Again, the fact that Ms. Maxwell may have "met and interacted with"
someone when they were a minor proves absolutely nothing.
2 One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter
should be given no legal weight in the Court's bail analysis. See United States V. Turner, 367 F. Supp. 2d 319, 331-
32 (E.D.N.Y. 2005)
3
EFTA00016775

=== Page 8 ===
as a substitute for its prosecution of Epstein. 3 The government's case is not what it represented
to the Court at the initial bail hearing, which should weigh heavily in favor of granting bail. 4
II.
The Government Has Not Carried Its Burden
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse
The government incorrectly argues that the renewed bail application offers no new
information and that the Court was "already aware of" the defendant's friends and family in
the United States. (Gov. Mem. at 13). The government ignores that, since the initial bail
hearing, Ms. Maxwell's spouse has come forward as a co-signor and has submitted a
detailed letter describing his committed relationship with Ms. Maxwell for over four years
and the important role she has played, and continues to play,
It also ignores that several of Ms. Maxwell's closest friends and family, many of
whom are U.S. citizens and residents, have also come forward, at considerable personal risk,
to support her bond with pledges of assets or letters of support. This information, which
was not available to the Court at the time of the initial hearing, demonstrates Ms. Maxwell's
strong ties to this country and weighs heavily in favor of bail.
Rather than address the merits, the government attempts to dismiss the significance
of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial
Services that she was in the process of getting a divorce and that her spouse did not step
forward as a co-signer at the initial bail hearing. (Id. at 13-14). The government is entirely
3 Moreover, the government failure to request
regardless of whether it was legally obligated to
do so, shows that the government has accepted the accusers' accounts without serious scrutiny. Given the
government's ongoing Brady obligations, it is unsettling that the government would simply accept
4 Contrary to the government's assertion, the defense has not abandoned our legal challenges to the indictment.
(Gov. Mem. at 10 n.1). We believe we have strong arguments that have only gotten stronger with the production of
discovery. We will be making those arguments to the Court in our pretrial motions to be filed next month.
4
EFTA00016776

=== Page 9 ===
mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting
a divorce as an additional way to create distance between Ms. Maxwell and her spouse to
protect him
from the terrible consequences of being associated with her.
Nevertheless, in the weeks following the initial bail hearing,
She and her spouse therefore had no reason to continue
discussing divorce, which neither of them wanted in the first place. Nor was there any
reason for her spouse to refrain from stepping forward as a co-signer. In sum, the
government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell's
relationship with her spouse
is not a powerful tie to this country.
The government's assertion that Ms. Maxwell must not have a close relationship
wit
particularly callous
and belied by the facts. (Gov. Mem. at 14). As her spouse explains,
(Ex. A 1 12).
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of
Her and Her Spouse's Assets in Support of Her Bond
The government's attempts to rebut the financial condition report are unavailing.
Significantly, the government does not contest the accuracy of the report, nor the
voluminous supporting documentation. In fact, the government has proffered nothing that
calls into question the report's detailed account of Ms. Maxwell and her spouse's assets for
the last five years, which addresses one of the Court's principal reasons for denying bail.
Rather than question the report itself, the government attempts to argue that Ms.
Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23).
5
EFTA00016777

=== Page 10 ===
The report shows nothing of the sort. Ms. Maxwell, who was sitting in a jail cell at the time,
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements. 5
The government's arguments further confirm that it has lost all objectivity and will
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated "sophistication in hiding her assets"
and characterizes her transfers to a trust as "funneling" assets to her spouse to "hide her true
wealth." (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
The government further argues that the financial condition report shows that Ms.
Maxwell has access to millions of dollars of "unrestrained funds" that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spous
could only be liquidated with considerable difficulty.
The government also faults Ms. Maxwell for not including a valuation of future
contingent assets and income that may never materialize. (Id. at 23-24). For example
5 Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
6
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Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to
is gratuitous. Ms. Maxwell had no knowledge of
But the larger point is this: Ms. Maxwell has proposed a substantial bail package
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell's wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that. 6
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
The government continues to assert the sinister narrative that Ms. Maxwell had "an
expertise at remaining hidden," and that it would therefore be easy for her to become a fugitive.
6 The government's argument that her spouse's moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse
will be
left with nothing. Furthermore, the government's assertion that they could not verify the spouse's financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse's current banking records and only redacted the name of the bank.
7
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=== Page 12 ===
(Gov. Mem. at 20). The government suggests that purchasing a home using a trust and providing
a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding
and somehow forecast Ms. Maxwell's intention to flee. (Id.). These arguments are just further
evidence that the government will frame every fact about Ms. Maxwell in the worst possible
light. As the defense has already argued extensively in its initial brief, these steps were borne
out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.
Moreover, they are not predictive of flight. There is simply no basis to conclude, based on the
measures that Ms. Maxwell was forced to take to protect herself and her family, that she would
then willingly abandon that family to become a fugitive from justice. To the contrary, she
remained in the country precisely to remain close to them and to defend her case.
D.
Extradition from France or the United Kingdom Is Highly Unlikely
The government dismisses Ms. Maxwell's willingness to waive her extradition rights as
to France and the United Kingdom as "meaningless" because Ms. Maxwell cannot guarantee
with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The
government misses the point: Ms. Maxwell's willingness to do everything she can to eliminate
her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment
to remain in this country to face the charges against her and, as Ms. Maxwell's French and U.K.
experts confirm, there is every reason to believe that both authorities would consider the waiver
as part of any extradition request.
In an attempt to counter William Julié's expert report stating it is "highly unlikely" that
the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the
government attaches a letter from the French Ministry of Justice ("MOJ") that references neither
Mr. Julié's report nor Ms. Maxwell, but states generally that the French Code of Criminal
Procedure "absolutely prohibits" the extradition of a French national. (Gov. Mem., Ex. B). But
8
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=== Page 13 ===
as Mr. Julié's accompanying rebuttal report explains (see Ex. A), the MOJ letter ignores that the
extradition provisions in French Code of Criminal Procedure apply only in the absence of an
international agreement providing otherwise. (Id. at 1). This rule is necessitated by the French
Constitution, which requires that international agreements prevail over national legislation. (Id.).
Thus, extradition of a French national to the United States is legally permissible if the extradition
treaty between the United States and France provides for it-which it does. (Id. at 3).
The government's reliance on a 2006 case-in which France refused to extradite a
French national who was also a U.S. citizen-provides no precedent as to how a French court
would rule on an extradition request regarding Ms. Maxwell because, as Mr. Julié notes, the
United States did not challenge the refusal in the French courts. (Id. at 2-3). Nor does it
undermine Mr. Julié's opinion that, in the unusual circumstance where a citizen of both countries
has executed an extradition waiver and then fled to France in violation of bail conditions set by a
U.S. court, it is "highly unlikely" that an extradition decree would not be issued. (Id. at 3).
The government offers no rebuttal to the opinion of Ms. Maxwell's U.K. extradition
expert, David Perry. Nor does it dispute Mr. Perry's opinion that Ms. Maxwell would be "highly
unlikely" to successfully resist extradition from the United Kingdom, that her waiver would be
admissible in any extradition proceeding, and that-contrary to the government's representation
at the initial bail hearing (Tr. 27)-bail would be "extremely unlikely." (See Def. Mem. Ex. U at
1 39). Mr. Perry's addendum opinion (attached as Ex. B) reiterates these points, opining that the
waiver would be "a highly relevant factor" in the U.K. proceeding, both to the likelihood of
extradition and to the likelihood of bail while the proceeding is pending. (Id. 3).⁷
7 Nor, as the government suggests, does the Secretary of State have general "discretion to deny extradition" after a
court has entered a final extradition order. (See Gov. Mem. at 19). That discretion is limited to a handful of
exceptional circumstances that would likely be inapplicable to Ms. Maxwell's case. (Id. " 4-5).
9
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=== Page 14 ===
Finally, the government's argument that Ms. Maxwell could always flee to some country
other than the United Kingdom and France holds her-and any defendant-to an impossible
standard, which is not the standard under the Bail Reform Act. (See Gov. Mem. at 19). By the
government's reasoning, no defendant with financial means to travel could be granted bail,
because there would always be a possibility that they could flee to another country (even if they
had no ties there), and there could never be an assurance that any extradition waiver would be
enforced. However, "Section 3142 does not seek ironclad guarantees." United States V. Chen,
820 F. Supp. 1205, 1208 (N.D. Cal. 1992). To the extent that Ms. Maxwell's ties to France and
the United Kingdom-where she has not lived for nearly 30 years-create a flight risk, her
extradition waivers along with the substantial bail package proposed reasonably cure it.8
E.
The Recent COVID Surge at MDC Further Justifies Bail
The government suggests that the Court ignore COVID concerns because Ms. Maxwell,
though quarantined because of contact with an officer who tested positive, did not become
infected. This ignores the daily (sometimes multiple) inspections of Ms. Maxwell's mouth,
which heightens her risk of contracting the deadly virus, which has now surged to 113 positive
cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t
has not been determined whether legal calls and legal visits will continue." As the Court is well
aware, legal visits with Ms. Maxwell already have been suspended. Should legal calls also be
discontinued, her constitutional right to effective assistance of counsel will be further eroded.
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her
release on bail pursuant to the strict conditions she has proposed.
8 Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France
of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g.,
France Details Modeling Agent in Jeffrey Epstein Inquiry, https://www.theguardian.com/world/2020/dec/17/france-
detains-modelling-agent-jean-luc-brunel-in-jeffrey-epstein-inquiry.
10
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=== Page 15 ===
Dated: December 18, 2020
Respectfully submitted,
/s/ Mark S. Cohen
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone:
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone:
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone:
Attorneys for Ghislaine Maxwell
11
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=== Page 1 ===
From:
To:
Subject: RE: GM appeal
Date: Mon, 14 Sep 2020 13:26:57 +0000
Attachments: Government_MTD_GM_Interlocutory_Appeal_v3.docx
Sorry, use this version instead (also on the share).
From:
Sent: Monday, September 14, 2020 12:06 AM
To:
Subject: RE: GM appeal
Complete draft attached and saved on the share. Once you have a draft of the letter, want to swap and do a final read of
each other's drafts before sending to
?
From:
Sent: Sunday, September 13, 2020 5:45 PM
To:
Subject: Re: GM appeal
Updated copy is the appeals folder- it's not great, so let me know your thoughts and how else I can help with this. I'm
around all evening and have also carved out time tomorrow to make sure we are covered on this. Do you want me to draft
the (short) amicus letter?
Sent from my iPhone
On Sep 13, 2020, at 11:28 AM,
wrote:
No problem-l've gone ahead and started on the MTD. Will work on it for the next hour or so, then send to you to pick
up.
From:
Sent: Sunday, September 13, 2020 11:26 AM
To:
Subject: Re: GM appeal
Hi! I ended up just blocking off today to do this
(
is gone for the day), so I haven't gotten anywhere yet (sorry about
that) but am hopeful to knock this out today. Do you want to split topics, as we discussed, and merge later? Happy to do
this any way that works.
Sent from my iPhone
On Sep 13, 2020, at 10:36 AM,
wrote:
Hey-have you started a draft of either document? I'm diving in now, so happy to pickup wherever you left off, or get
them started if you haven't had the chance.
Assistant United States Attorney
EFTA00016308

=== Page 2 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein search warrant materials
Date: Tue, 12 Nov 2019 19:15:24 +0000
I am generating the load files for such stuff as we speak. Apologies for the delays, this is a long and complex
process that I had to come up with a procedure for. I anticipate the files being ready by the Thursday COB. If you
could forward a drive to me to copy the files onto, I would appreciate it.
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:11 PM,
)"
wrote:
Wanted to follow up on our phone conversation from about six weeks ago - I think we had anticipated that the electronic
evidence that was being processed by CART from the New York residence search (which I believe was whittled down to
approximately 5-6 iMacs and 5 laptop computers) would be completed for upload with load files for Relativity sometime
in late October. We're concerned about timing particularly because I think that's just the tip of the iceberg - I don't think
FBI has even started on the island materials, for example - so wanted to check on timing. Could you please let us know
what the status is of those materials, and also what the materials are from the island that need to be processed, and
whether there's an estimated time of completion for those as well?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: RE: Request re Maxwell Relativity
Date: Tue, 08 Dec 2020 21:41:08 +0000
Inline-Images: image001.jpg
Hi
I've reviewed the search and confirmed that those documents should all be marked Non-Responsive and locked off from
being accessed.
I am fine with the Non-Responsive data being placed in subfolders as you suggest, as long as all of the Non-Responsive
documents are locked off from review.
Thanks very much,
From:
(USANYS) [Contractor]
Sent: Tuesday, December 8, 2020 10:07 AM
To:
Cc:
>;
(USANYS)
Subject: RE: Request re Maxwell Relativity
Hello
Can you please confirm that the below search is the correct data to secure:
US V. Epstein (SW Returns) - Potentially Non-Responsive - https://d1pe.nss.pae.com/Relativity/go?id=2370462-4350955
Can you also please confirm that the Potentially Non-Responsive data will be placed in two subfolders under the following
parent folders:
Search Warrant Returns
New_Search Warrant Returns_FBI
USVE_20200728
Thank you.
From:
)
Sent: Friday, December 4, 2020 10:55 AM
To:
(USANYS) [Contractor]
EFTA00016526

=== Page 2 ===
Cc:
is
(USANYS)
Subject: Request re Maxwell Relativity
Now that we have completed our responsiveness review in the "US V Epstein (SW Returns)" database, we need to lock off
access to any non-responsive materials in that database. Would it be possible to please lock off access to the 397,365
documents in that database that are NOT currently tagged "Identified Responsive"? That should leave just the 1,218,719
documents that are tagged "Identified Responsive" accessible to the team for use in our case.
Happy to have a call to discuss if that would be useful.
Thanks very much,
EFTA00016527


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
)"
)"
Subject: Maxwell victim website
Date: Wed, 20 Oct 2021 17:13:15 +0000
Attachments: 2021.10.19_Order_re_October_21_Teleconference.pdf
Hi
Judge Nathan issued the attached order regarding the teleconference set for tomorrow. Would you be able to update the
victim website with this info, please? Some proposed language below.
The Court will hold a telephone conference to discuss jury selection matters on October 21, 2021 at 12:00 p.m. Members
of the press and the public in the United States may access the live audio feed of the proceeding by calling
and using access code 9991787. Those outside of the United States may access the live audio feed by calling
and using the same access code. Any photographing, recording, or rebroadcasting of federal court
proceedings is prohibited by law.
Thanks very much,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
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=== Page 1 ===
Page 1 of 1
INEW YORK POST
EPSTEIN EYES SEX-RAP RELIEF
October 9, 2007 - LAWYERS for Jeffrey Epstein - the billionaire Manhattan
STAPLES
S
investment manager who's agreed to plead guilty to soliciting underage
prostitutes at his Palm Beach mansion in exchange for just 18 months in the
slammer - are mulling asking federal prosecutors to drop their demand that he
register as a sex offender. In a letter drafted, but not sent, to U.S. Attorney
Business-
Alexander Costa and obtained by Page Six, Epstein's lawyer, Gerald
Lefcourt, writes, "Doing so will have a profound impact [on Epstein] both
Bundle-A-Day
immediately and forever after. Not only will he be restricted to a wholly
inappropriate penal facility, but he will be required for the rest of his life to
GIVEAWAY
account for his whereabouts." Epstein, a former business partner of Daily
News owner Mort Zuckerman, pleaded guilty to a state charge in exchange
Enter daily to win an
for the feds' dropping their probe into possible federal criminal violations.
incredible prize package
Lefcourt argues that only the feds have demanded that Epstein register,
for your office.
"despite the fact that the state was of the view that Mr. Epstein's conduct did
There's a new winner
not warrant registration." A rep for Epstein had no comment.
every business day!
:- Enter now
Valued at
more than
550!
Home
NEW YORK POST is a registered trademark of NYP Holdings, Inc. NYPOST.COM, NYPOSTONLINE.COM and
NEWYORKPOST.COM
are trademarks of NYP Holdings, Inc.
Copyright 2008 NYP Holdings, Inc. All rights reserved.
http://www.nypost.com/php/pfriendly/print.php?url=http://www.nypost.com/seven/1009200. 6/3/2008
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=== Page 1 ===
10/6/21, 12:30 PM
NCIC Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
Federal NCIC
WARNING: Release of any NCIC information to unauthorized individuals or agencies,including the subject of the
data, is prohibited. Please refer to section 4.2 of the CJIS security policy and Title 28, Part 20 of the code of
Federal Regulations for the proper acess, use, and dissemination of the information contained in the NCIC
restricted and non-restricted files.
The following information is provided in response to your request for a search of the NCIC - Protection Order File based on:
DNA/N
ORI IS LOS ANGELES CO so LOS ANGELES
PC0/04 - THE SUBJECT IS REQUIRED TO STAY AWAY FROM THE RESIDENCE, PROPERTY,
PCO/SCHOOL, OR PLACE OF EMPLOYMENT OF THE PROTECTED PERSON OR OTHER FAMILY OR
PCO/HOUSEHOLD MEMBER.
PCO/05 - THE SUBJECT IS RESTRAINED FROM MAKING ANY COMMUNICATION WITH THE
PCO/PROTECTED PERSON INCLUDING BUT NOT LIMITED To, PERSONAL, WRITTEN, OR
PCO/TELEPHONE CONTACT, OR THEIR EMPLOYERS, EMPLOYEES OR FELLOW WORKERS, OR
PCO/OTHERS WITH WHOM THE COMMUNICATION WOULD BE LIKELY TO CAUSE ANNOYANCE OR
PCO/ALARM THE VICTIM.
PC0/07 - THE SUBJECT IS PROHIBITED FROM POSSESSING AND/OR PURCHASING A FIREARM
PCO/OR OTHER WEAPONS AS IDENTIFIED IN THE MISCELLANEOUS FIELD.
PC0/09 - THE PROTECTED PERSON IS AWARDED TEMPORARY EXCLUSIVE CUSTODY OF THE
PCO/CHILD(REN) NAMED.
1/1
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=== Page 1 ===
From: "Robert Y. Lewis"
To:
Cc:
)"
,
"James R. Marsh" <jamesmarsh@marsh.law>
Subject: [EXTERNAL] USA V. Maxwell -- 20-CR-330 (AJN)
Date: Wed, 27 Oct 2021 18:52:02 +0000
Inline-Images: Outlook-jinknu5v.png; Outlook-NCVBA.png
Dear Ms.
and Mr. Pecorino:
I represent
a victim of the sex trafficking crimes alleged to have been perpetrated by Jeffrey
Epstein and his alleged lieutenant Ghislaine Maxwell. Ms.
was one of the Epstein victims who spoke to
deliver a victim impact statement in front of Judge Berman on August 29, 2019, when Judge Berman dismissed
the Epstein indictment due to Epstein's apparent suicide.
As you know, the criminal trial of Ms. Maxwell is scheduled to commence on November 29, 2021 before Judge
Nathan. Ms.
would like to attend the trial. Could you please advise me as to what protocols will be
followed for obtaining admission to the trial either in the courtroom or the overflow rooms. Ms.
is
travelling from
so it is important that there be some reasonable likelihood that she will be able to
attend the trial once here.
Best regards,
Robert Y. Lewis
The Marsh Law Firm PLLC
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2021
THE NATIONAL
CRIME VICTIM
BAR ASSOCIATION
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and may be subject to the
attorney-client privilege, or otherwise protected from disclosure by applicable law. Any disclosure, distribution, copying, or use of
the information contained in this message or any attachment by anyone other than the intended recipient, regardless of address or
routing, is strictly prohibited. If you are not the intended recipient, please telephone or email the sender and delete this message
and any attachment from your system.
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential
and may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law.
Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by
EFTA00015345

=== Page 2 ===
anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the
intended recipient, please telephone or email the sender and delete this message and any attachment from your
system.
IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not legal
advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC for the
provision of legal services, unless explicitly so stated herein. Any attached items, including the content of this e-
mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or completeness.
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=== Page 1 ===
Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 Page 1 of 6
PANISH
SHEA &
BOYLE
LLP
August 27, 2020
VIA ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, NY 10007
Re:
Doe V. Indyke, et al., 1:20-cv-000484-JGK-DCF
Plaintiff's Opposition Letter to Defendant Ghislaine Maxwell's Letter Motion
to Stay Proceedings
Dear Judge Freeman:
On behalf of plaintiff Jane Doe in the above-referenced litigation, we hereby submit this
opposition to defendant Ghislaine Maxwell's Motion to Stay.
INTRODUCTION
On August 19, 2020, defendant Maxwell wrote to this Court requesting that it stay this
case until the conclusion of her pending criminal case in which she is accused of recruiting and
enticing minors to travel to engage in illegal sex acts. The trial in that case is not currently
scheduled to commence until July of 2021.
Defendant Maxwell's leading argument in support of her request is that she is unable to
defend herself in this case while she is in jail and awaiting trial in the criminal case. Prior to
filing her request to halt these proceedings, however, defendant Maxwell, through her counsel,
filed her answer to Plaintiff's complaint over one month ago, participated in a case management
conference with the Court on August 5 and has engaged in numerous email exchanges and phone
calls with the other parties concerning setting depositions and case deadlines. Moreover, even
after asking the Court to stay this case on August 19 because it would purportedly be a "burden"
on her to defend this case under her current circumstances, defendant Maxwell propounded
discovery on Plaintiff just two days later on August 21 seeking a wide variety of information and
documents from her. Defendant Maxwell's thinly veiled argument that her criminal case is
somehow preventing her from doing what she needs or wants to do in this case is undermined by
the record of what has actually occurred. Rather, defendant Maxwell appears to want to gain an
unfair advantage by acquiring as much information as she can about Plaintiff without having to
divulge anything about herself or the bad conduct she is alleged to have committed.
11111 Santa Monica Boulevard, Suite 700
Los Angeles, California 90025
310.477.1700 phone
310.477.1699 fax
www.psblaw.com
EFTA00016286

=== Page 2 ===
Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 PANISH
SHEA &
Hon. Debra C. Freeman
BOYLE
Daniel Patrick Moynihan
LLP
United States Courthouse
August 27, 2020
Page 2
Defendant Maxwell's other main argument is that Plaintiff is somehow doing something
foolish or inappropriate by not staying her case in order to "pursue a civil remedy in the Epstein
Claims Resolution Program." She argues that Plaintiff is "inexplicably the only of the numerous
Epstein plaintiffs in this Court to not agree to such a stay" and that "a stay also would permit
[Plaintiff] the opportunity to [participate in the Epstein victim claims program]." Defendant
Maxwell then falsely claims that "Plaintiff has not advanced a cogent reason for wanting to press
ahead alone." Not so. Plaintiff is seeking to hold defendant Maxwell accountable for the
heinous and sick sexual acts she committed against Plaintiff over the course of several years
while Plaintiff was just a child. Pausing this lawsuit for approximately one year or more, as
defendant Maxwell is requesting, would in no way help Plaintiff accomplish that objective
despite defendant Maxwell's self-serving arguments to the contrary. Instead, it would simply
delay long overdue justice for Plaintiff.
Moreover, while defendant Maxwell would have this Court and the public believe that
Plaintiff has to choose between pursuing her claims in this case or participating in the Epstein
victim claims program, nothing could be further from the truth. Indeed, the protocol for the
claims program explicitly states that: "Individuals who have filed a lawsuit need not agree to a
stay of litigation or make any other concession in any pending litigation to be eligible to
participate in the Program." Despite this straightforward and sensible provision in the claims
program protocol, defendant Maxwell has underhandedly attempted to persuade the Court that
should a stay be entered it would "permit" Plaintiff to participate in the claims program. Plaintiff
does not-and should not-have to choose between her civil lawsuit and participating in the
claims program. And the last thing Plaintiff needs is for Ghislaine Maxwell to pretend that by
putting a stop to this case she would somehow benefit by being "permitted" to participate in the
claims program. Plaintiff does not need permission by defendant Maxwell or anyone else to
exercise her legal rights.
Defendant Maxwell's motion does not meet the high burden required by the law to justify
an extraordinary remedy as a stay of proceedings in this case. For the reasons set forth above
and those that follow, Plaintiff respectfully requests that the Court deny defendant Maxwell's
request to stay this case. If, however, the Court is inclined to grant a stay at all, Plaintiff submits
that it should be as to the entire action and not just as to discovery directed to defendant Maxwell
as counsel pointed out was the case in Farmer V. Indyke, 19-cv-10475-LGS-DCF. Otherwise,
defendant Maxwell would be given the unfair advantage of collecting evidence from others and
taking part in the questioning of witnesses at depositions while at the same time silently hiding
behind a court order blocking anyone from doing the same as to her.
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Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 PANISH
SHEA &
Hon. Debra C. Freeman
BOYLE
Daniel Patrick Moynihan
LLP
United States Courthouse
August 27, 2020
Page 3
LEGAL STANDARD
A stay of a civil case to permit conclusion of a related criminal prosecution has been
characterized as an "extraordinary remedy." Louis Vuitton Malletier S.A. V. LY USA, Inc., 676
F.3d 83, 98 (2d Cir. 2012) (emphasis added). As a result, a civil defendant urging a stay pending
a parallel criminal prosecution bears the burden of establishing its need. Rex & Roberta Ling
Living Tr. V. B Commc' 'ns Ltd., 346 F. Supp. 3d 389, 400 (S.D.N.Y. 2018). "[A]bsent a showing
of undue prejudice upon defendant or interference with his constitutional rights, there is no
reason why plaintiff should be delayed in its efforts to diligently proceed to sustain its claim."
Id. at 97.
When determining whether a stay should be granted or denied, a court must undergo "a
particularized inquiry into the circumstances of, and the competing interests in, the case." Louis
Vuitton Malletier S.A., 676 F.3d at 99. Courts in this District conduct the particularized inquiry
guided by the following six factors which are balanced when considering a stay: 1) the extent to
which the issues in the criminal case overlap with those presented in the civil case; 2) the status
of the case, including whether the defendants have been indicted; 3) the private interests of the
plaintiffs in proceeding expeditiously weighed against the prejudice to plaintiffs caused by the
delay; 4) the private interests of and burden on the defendants; 5) the interests of the courts; and
6) the public interest. Id. at 99.
Critically, the balancing of these factors "can do no more than act as a rough guide for the
district court as it exercises its discretion." Id. These factors "do little more than serve as
something of a check list of factors [the appellate court] ought to consider" when reviewing a
lower courts determination. Ultimately, though, the court must rely on nothing more than its
studied judgment "based on the particular facts before it and the extent to which such a stay
would work a hardship, inequity, or injustice to a party, the public or the court." Id.
A STAY OF ALL PROCEEDINGS HARMS PLAINTIFF'S INTERESTS
Defendant Maxwell argues that a stay in the litigation benefits Plaintiff. Not so. First, as
discussed above, defendant Maxwell asserts that staying the litigation would "permit [Plaintiff]
the opportunity" to participate in the Epstein victim claims program. Defendants Maxwell's
implication is obvious: if Plaintiff continues to litigate, she cannot participate in the program.
That is categorically false. Whether or not Plaintiff participates, the program explicitly states that
a stay of any participant's civil proceedings is not required in order to participate.
Defendant Maxwell also asserts that participation in the claims program will "obviat[e]
the need for this case to proceed at all." Defendant Maxwell knows, however, that participation
EFTA00016288

=== Page 4 ===
Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 PANISH
SHEA &
Hon. Debra C. Freeman
BOYLE
Daniel Patrick Moynihan
LLP
United States Courthouse
August 27, 2020
Page 4
in the claims program is not binding and that victims of Epstein and Maxwell are free to reject
any offer made in the program in favor of pursuing damages through litigation.
Lastly, defendant Maxwell callously suggests that because Plaintiff's abuse occurred 26
years ago, there is "hardly much harm" in delaying Plaintiff's "stale" claims. The fact, however,
that Epstein and Maxwell started to abuse Plaintiff when she was a 14-year-old girl-26 years
ago-does not negate the ongoing damaging effects that abuse has had and continue to have on
Plaintiff.
Simply put, a stay would harm-not benefit-Plaintiffs interests. For too long Jeffrey
Epstein and Ghislaine Maxwell skirted the consequences of their vile acts. Now, Plaintiff brings
this suit, as is her right by law, to hold the Epstein Estate and defendant Maxwell to answer.
Plaintiff is best served by pressing forward with her claims-not waiting even longer for justice.
Sadly, defendant Maxwell's seeking a stay is consistent with her decades-long routine of
resisting accountability for sexually abusing minors. As a result, her request for a stay should be
denied.
CONTINUED CIVIL LITIGATION WILL NOT BURDEN MAXWELL WHO
HAS ACTIVELY PARTICIPATED IN THE CASE FROM JAIL
Next, defendant Maxwell argues the burden on the Defendant militates in favor of a stay.
Defendants Maxwell states that the burden of proceeding with this litigation "cannot be
overstated." However, a particularized inquiry into defendant Maxwell's complaints about the
difficulty of proceeding with the civil case while incarcerated reveal a stark contradiction.
Indeed, defendant Maxwell has already been actively participating in this litigation from jail for
months. Here is a relevant timeline:
On July 2, 2020, Ghislaine Maxwell was arrested while hiding out in New Hampshire.
On July 9, 2020, from jail, defendant Maxwell filed an answer in this case. Since then,
defendant Maxwell through her counsel has actively participated in the litigation, including
scheduling depositions, conferring several times with counsel for Plaintiff and the Epstein Estate,
and appearing before this Court.
On August 19, 2020, from jail, defendant Maxwell filed this motion to stay proceedings.
Despite complaining of the monstrous burden imposed by litigating from jail, two days later, on
August 21, 2020, Maxwell served discovery requests on Plaintiff, including sixteen
interrogatories and twenty-four requests for production of documents.
EFTA00016289

=== Page 5 ===
Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 PANISH
SHEA &
Hon. Debra C. Freeman
BOYLE
Daniel Patrick Moynihan
LLP
United States Courthouse
August 27, 2020
Page 5
Clearly, defendant Maxwell wants to use her incarceration both as a shield and a sword:
arguing that it is simply too much to litigate from jail, while at the same time, pressing ahead in
her attempts to undermine Plaintiff's claims. Clearly, the burden on defendant Maxwell is not
great.
THE PUBLIC INTEREST IS BEST SERVED BY ALLOWING PLAINTIFF'S
CLAIMS TO PROCEED
In her motion, defendant Maxwell entirely fails to address why the public interest is
served by a stay. That is because the public interest is not served by a stay; the public is best
served by allowing Plaintiff's claims against defendant Maxwell-the only actively litigated
claims against her currently-to proceed in full public view.
Courts in the Second Circuit recognize that the public benefits from civil litigation not
only when it advances the justifiable interests of the Plaintiff, but also when the litigation
furnishes the public with information on the torts and crimes of a wrongdoer. See Louis Vuitton
Malletier S.A., 676 F.3d at 103 (citing SEC V. Dresser Indus., 628 F.2d 1368, 1372
(D.C.Cir.1980) (en banc) (denying a stay in order to avoid the continued dissemination of false
or misleading information by companies to members of the investing public). In Louis Vuitton
Malletier S.A., the Second Circuit upheld the denial of a criminal and civil defendant's request
for a stay of the civil litigation in part because, to the public's benefit, the litigation uncovered
evidence that the defendant was running a counterfeiting operation. See id.
For years defendant Maxwell and Jeffrey Epstein were at the center of a criminal
enterprise geared towards sexually abusing minor girls and getting away with it. Plaintiff's
lawsuit is the only case currently being litigated against her-all others have either been stayed
or dismissed. While Plaintiff has much to gain through this litigation, so too does the public.
The continuation of this last remaining civil avenue can furnish the public with critical
information as to defendant Maxwell's well known criminal enterprise, how it was operated and
all those involved. A stay of the civil proceedings would provide what defendant Maxwell has
sought for years-concealing her heinous acts from public view.
MAXWELL'S EXTRAORDINARY REQUEST FOR A STAY SHOULD NOT BE
GRANTED SIMPLY BECAUSE SHE HAS BEEN INDICTED AND CLAIMS
THERE IS OVERLAP BETWEEN THE INDICTMENT AND PLAINTIFF'S
COMPLAINT
Defendant Maxwell also argues that because of her indictment and an overlap between
Plaintiff's complaint and the indictment, she is entitled to a stay. However, a defendant in both a
EFTA00016290

=== Page 6 ===
Case 1:20-cv-00484-JGK-DCF Document 78 Filed 08/27/20 PANISH
SHEA &
Hon. Debra C. Freeman
BOYLE
Daniel Patrick Moynihan
LLP
United States Courthouse
August 27, 2020
Page 6
civil and criminal matter, like defendant Maxwell here, has "no absolute right not to be forced to
choose between testifying in a civil matter and asserting [her] Fifth Amendment privilege." Louis
Vuitton Malletier S.A., 676 F.3d at 98 (quoting Keating V. Office of Thrift Supervision, 45 F.3d
322, 326 (9th Cir. 1995)). In fact, "[t]he existence of a civil defendant's Fifth Amendment right
arising out of a related criminal proceeding thus does not strip the court in the civil action of its
broad discretion" to move the case along. See Louis Vuitton Malletier S.A., 676 F.3d at 98-99.
Defendant Maxwell has no absolute right to stay this case simply because she has been
indicted. Instead, the Court must conduct its own particularized inquiry into the facts at hand
when deciding whether to grant her request. As she has demonstrated throughout this litigation,
during which time she has been both indicted and incarcerated, defendant Maxwell is not unduly
burdened by continued litigation.
For the foregoing reasons, Plaintiff respectfully requests that the Court deny defendant
Maxwell's request to stay this case.
Respectfully submitted,
PANISH SHEA & BOYLE
/s/ Robert Glassman
Robert Glassman
cc: All counsel of record
EFTA00016291


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=== Page 1 ===
From:
To: Christian Everdel
BOBBI C STERNHEIM
Jeff Pagliuca
, Laura Menninger
Cc:
Subject: Draft joint proposed request to charge
Date: Wed, 20 Oct 2021 16:29:51 +0000
Attachments: Maxwell_RTC_[2021.10.21_to_defense_counsel].docx
Counsel,
Attached please find a draft joint proposed request to charge. Since this is due to the Court on Wednesday, October 27,
please send us your comments by Sunday, October 24. Please also send us your comments, including any additional
proposed jury instructions, as a redline to this document.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00016953


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: FW: [EXTERNAL] Fw: Maxwell classified ads
Date: Tue, 30 Nov 2021 14:47:20 +0000
Attachments: Citations.pdf;Jan_4_1997_The_Palm_Beach_Post_page_58.PNG
Inline-Images: Jan_3_1997_The_Palm_Beach_Post_page_145.PNG;
Janury_3_1997_Palm_Beach_Daily_News_page_6.PNG
Assuming he already sent to you.
From: Thomas Volscho
Sent: Monday, November 29, 2021 10:04 PM
To:
(USANYS)
Subject: [EXTERNAL] Fw: Maxwell classified ads
FYI
Sent with ProtonMail Secure Email.
Original Message
On Monday, November 29th, 2021 at 9:51 PM, Thomas Volscho
wrote:
Dear AUSA
Please find attached several classified advertisements from 1997 and Ghislaine Maxwell 1996 traffic citation with
matching phone number. Used in Daily Mail story.
https://www.dailymail.co.uk/news/article-10252175/Ghislaine-Maxwell-launched-hiring-drive-recruits-answer-phones-
trafficked-girls.html
Sent with ProtonMail Secure Email.
DVV DE 1008
PERSON needed for answer
ing phones & light cleaning
during School Holidays Call
Miss Maxwell,
PET STORE CLERK FT. Ap.
ply in person PETPOURRI, 75
E. Indiantown Rd. Jupiter.
VALET PARKERS
Fulltime & Parttime positions available. in
Boynton Beach. Call Christian at
PERSON NEEDED TO ANSWER TELEPHONES
& Do Light Cleaning Work During School
Holidays. Please Call Ms. Maxwell
HOUSEKEEPER/COOK
Livein/Out, Experienced Necessary, References
Required, Year Round Position. Call
EFTA00016521


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=== Page 1 ===
From: "Strauss, Audrey (USANYS)"
To:
)"
(USANYS)"
(USANYS)"
i
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
)"
)"
Subject: RE: letter to Epstein estate trustees' counsel
Date: Sat, 25 Jul 2020 15:30:52 +0000
Attachments: AS_COMMENTS_TO_JE_letter_to_trustees_counsel.docx
Thanks
Attached are some suggested comments to the letter.
Feel free to give me comments.
Audrey
From:
Sent: Thursday, July 23, 2020 5:12 PM
To: Strauss, Audrey (USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
Subject: RE: letter to Epstein estate trustees' counsel
Team, we understand you've asked us to draft a letter to the executors of Epstein's estate (who are also the co-trustees of
the 1953 Trust Agreement) on a couple issues - a draft is attached for your review. We've also included a question about
any waiver of attorney-client privilege, which will be helpful to have their position on in connection with our discovery
review and production process.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00015846


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=== Page 1 ===
H. DOHN WILLIAMS JR.
Attorney at Law
Over 45 Years' Experience
Martindale-Hubbel "AV" Rated
Trials & Appeals, State & Federal Courts
July 19, 2019
U.S. Attorney's Office
Re:
USA V. Jeffrey Epstein
Dear
The bullet Epstein dodged that no one is talking about. He did so because of the combined
actions of former U.S. Attorney Alexander Acosta, former Palm Beach County State Attorney
Barry Krischer, the Palm Beach County Sheriff's Office, and the assistant state attorney(s) that
handled Jeffrey Epstein's criminal prosecution in state court.
At his plea and sentencing, the judge asked why Epstein was going to serve his sentence in
the Palm Beach County stockade instead of in a Florida state prison, like most sex offenders,
The response was we just decided that was the best way to accomplish what needed to be
done here and agreed that the sentence satisfied everyone's requirements.
His carefully constructed plea and sentence accomplished Epstein avoiding the Jimmy Ryce
Act, relating to the indefinite civil commitment of sexual predators. If he had been eligible for
Jimmy Ryce commitment, there is a substantial likelihood that he would have been indefinitely
committed and warehoused with other sexual predators.
Epstein was charged with two felony offenses: (1) procuring a person under the age of 18 for
prostitution, a second-degree felony, punishable by 15 years in prison, and (2) felony
solicitation of prostitution, a third-degree felony, punishable by 5 years in prison. He was facing
a maximum consecutive sentence of 20 years in prison.
Florida, like the Federal Courts, has sentencing guidelines. Epstein's guidelines calculated the
"lowest permissible prison sentence of 21.5 months," or almost two years in state prison. In
Florida, the court can go below the lowest permissible range via a motion for downward
departure, or plea bargain. Epstein avoided a 21.5-month prison system via plea bargain.
EFTA00014615

=== Page 2 ===
To understand how he avoided the Jimmy Ryce Act, you need to look at his carefully
constructed sentence. According to the plea sheet he signed, regarding his conviction for felony
solicitation of prostitution, he was sentenced to 12 months in the county jail. Regarding is
conviction for procuring a person under the age of 18 for prostitution, a second-degree felony,
he was sentenced to 6 months county jail consecutive to the above 12-month sentence, and
that term of incarceration was to be followed 12 months community control. In other words, he
was sentenced to 18 months incarceration in the county jail.
What if he had been sentenced to 18 months in prison, instead of the county jail? In 2008, the
Jimmy Ryce provided that to be eligible for indefinite civil commitment as a sexual predator the
person had to be:
serving a sentence in the custody of the Department of Corrections, a
person who was adjudicated delinquent and is committed to the custody of the
Department of Juvenile Justice, or a person who was involuntarily committed
to the custody of the Department of Children and Family Services upon an
adjudication of not guilty by reason of insanity. $394.912(1), Fla. Stat. (2008).
Defendants that might satisfy the definition of a sexual predator were excluded from
consideration if they were serving their time in a county jail. I have defended sex offenders and
men being prosecuted under the Jimmy Ryce Act. In 2005-2006, as an assistant public
defender, I defended about 25 menibeing prosecuted under the Jimmy Ryce Act. I advised
young public defenders to have sex crime offenders to take time in the county jail for this very
reason.
In 2008, an experienced sex crimes prosecutor would have been aware of this county jail
loophole.¹ If they say they were not aware of this loophole, they are incompetent or untruthful.
In 2014, this loophole was closed. The above section was amended to include, a person
who is serving a sentence in a county or municipal jail for a sexually violent offense. "
$394.912(1), Fla. Stat. (2014). Now, a defendant cannot avoid the Jimmy Ryce Act by doing
his time in the county jail, like Epstein.
For purposes of the Jimmy Ryce Act a "sexually violent offense" includes any criminal act that
is subsequently determined to be proven beyond a reasonable doubt to have been "sexually
motivated." A "sexually motivated" crime is one whose purpose, in part, was for sexual
gratification. Certainly, prostitution related offenses, and particularly with the facts of his case
were committed in part for sexual gratification. The misnomer is that violence does not have
to be an element of the crime.
If Epstein had been in prison, instead of the county jail, the Department of Children and Family's
Multidisciplinary Team would have evaluated Epstein and submitted its written assessment
and recommendation to State Attorney Barry Krischer. Epstein would have been back in the
I
A defense attorney cannot be faulted for getting a disposition that avoids Jimmy Ryce
consequences, because his duty is to his client.
2
EFTA00014616

=== Page 3 ===
State Attorney's lap for the filing a petition to seek his indefinite civil commitment. Once a
petition is filed, the offender is held in custody at the Florida Civil Commitment Center. There
is no bond/bail.
Having tired these cases, representing the defendant, the case is a battle of experts. The six-
person jury must unanimously find by clear and convincing evidence whether the person
has the requisite prior conviction, has a mental abnormality affecting a person's emotional
or volitional capacity which predisposes the person to a sex offense, and is likely to engage
in further sex crime to such a degree as to pose a menace to the health and safety of others,
unless he is indefinitely confined for treatment.
This potential "rabbit hole" was avoided simply by where Epstein was incarcerated.
In determining whether Epstein would satisfy the criteria for the State Attorney to file a petition
for involuntary commitment, the psychologist/psychiatrist. evaluators use a diagnostic tool
known as Static-99. It is used throughout the United States and Canada. See the attached
Static-99 form. Plus, the evaluators can go behind the mere charges that he pled to.
Having a familiarity with Static-99 evaluation forms while representing men who had petitions
filed against them, based on the Static-99, Epstein arguably qualified for the filing of a petition.
I am not an expert, but I rough calculated his score, using the score sheet applicable at the
time of his plea, as 4, which translates to a moderate to high risk of re-offending.
If Epstein was sentenced to state prison by the State Attorney Krischner, there is a likelihood
he would have been back in front of that same State Attorney for potential indefinite civil
commitment. Instead of recently returning from France, Epstein might still be at the facility in
Arcadia, Florida, with over 600 other sexual predators. Florida has more people committed
than any other state.
There are other anomalies in the handling of this case. He was indicted for the first charge
(2006CF9454). In the Federal system, felony prosecution is initiated by Indictment, or the
prosecutor and the defense agree to the file of an Information charging a specific crime(s). In
Florida, the only crime that requires an Indictment is first-degree murder. In Florida, the State
Attorney is referred to an a "one-man" grand jury because the State Attorney can with the stroke
of a pen initiate a criminal prosecution for any crime, other than first-degree murder. Over 98%
of crimes in Florida are charged by Information filed by an assistant state attorney.
According to The Miami Herald article, Detective Recarey also told The Miami Herald that in
May 2006, he drew up probable cause affidavits that charged Epstein and three associates
with a slew of sex crimes. But instead of pushing forward with the case, Krischer referred the
case to the grand jury, which returned an Indictment on a single count of soliciting prostitution.
In Florida state court, the prosecutor frames the charge it wants the grand jury to consider and
brings an Indictment and the applicable law and instructions.²
I would be curious how many indictments in Palm Beach County in 2005-2006 were returned
for crimes other than first-degree murder cases? How many sex crimes prosecutions were
2 As an assistant state attorney, I presented Indictments to the grand jury.
3
EFTA00014617

=== Page 4 ===
initiated by indictment? These questions a federal prosecutor unfamiliar with our state court
system might not ask.
Regarding the first case, there are over 140 docket entries. A demand for discovery was never
filed. If it had been filed, the State Attorney would have to file an answer. Under Florida law,
the answer is a public record, as well as most of the documents produced in conjunction with
the answer. This kept the facts out of the public eye.³
Regarding the second case (2008CF009381). an Information was filed June 26, 2008. But the
usual probable cause affidavit setting forth the facts of the crime was not filed.4 He plead guilty
four days later. Does the transcript of the plea colloquy set forth a factual basis, or did he
stipulate there was a factual basis?
In summary, with no probable cause affidavit in either case, or demand for discovery the public
has no idea about the facts supporting the charges. Epstein was sex offender like my former
public defender clients. But money, powerful friends, the U.S. Attorney, the Palm Beach State
Attorney and Sheriff's Office agreed to an unusual sentence structure whereby Epstein avoided
potential Jimmy Ryce Act indefinite civil commitment. Ask for proof that any other serial sex
offender was sentenced to more than 365 days incarceration and was permitted to serve his
time in the Palm Beach County Jail. I am not a hypocrite, as a criminal defense attorney, I too
would have sought to structure a sentence to avoid the Jimmy Ryce Act.
The defense obtained a spectacular outcome. But, the outcome was only possible because (1)
a U.S. Attorney's Office was apparently afraid to try a case that was less than a slam dunk
winner, (2) a state court prosecutor was apparently afraid to try a case that was less than a
slam dunk winner, and (3) a Sheriff who went along with the sentencing scheme. Ask the
sheriff how many times he has honored this type of sentencing arrangement.
Sincerely yours,
H. CO Dohn Williams Jr.
Cc:
U.S. Attorney's Office
U.S. Attorney's Office
3 A defense attorney should not be faulted for this tactic; it protects his client.
4 Go to the online court document number 4. It reads "rough arrest no probable cause filed"
4
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=== Page 1 ===
From:
To:
Subject: 21-770 United States of America V. Maxwell "Defective Document FILED"
Date: Mon, 05 Apr 2021 19:20:21 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/05/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
DEFECTIVE DOCUMENT, Acknowledgment and Notice of Appearance, [32], on behalf of Appellant Ghislaine
Maxwell, FILED.[3070417] [21-770]
Notice will be electronically mailed to:
Ms.
, Assistant U.S. Attorney:
,
David Oscar Markus, -:
Ms. Bobbi C. Sternheim, -:
The following document(s) are associated with this transaction:
Document Description: Defective_Document_Notice
Original Filename:
/opt/ACECF/live/forms/TammyTorres_21770_3070417_Defective_Document_Notice_142.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/05/2021] [FileNumber=3070417-0]
[82ac9d6638f4343e945c759f77acc6c8e4e4d8343df706156a85e0abeacb8b5b67869ed37fa359c625853ed7b4b22
b5ad7f3705c9d7151eb0697a6f103035bae]]
Recipients:
Ms.
Assistant U.S. Attorney
David Oscar Markus, -
EFTA00015723

=== Page 2 ===
Ms. Bobbi C. Sternheim, -
EFTA00015724


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=== Page 1 ===
From:
"
)"
To:
)"
)"
Cc:
)"
Subject: RE: [EXTERNAL] Re: GM - Witnesses
Date: Wed, 06 Oct 2021 21:19:56 +0000
Thanks! Could you please send us these files in PDF format? I'm having a hard time opening them.
From:
Sent: Wednesday, October 6, 2021 5:13 PM
To:
>;
Cc:
is
Subject: RE: [EXTERNAL] Re: GM - Witnesses
Good evening,
Attached is a word document containing the Accurint/Ejustice queries for the list of below individuals. Also attached are
the Ejustice/NCIC records for any positive result.
Thanks!
From:
Sent: Wednesday, October 6, 2021 3:51 PM
To:
Cc:
>;
)
>;
Subject: [EXTERNAL EMAIL] - Re: [EXTERNAL] Re: GM - Witnesses
On Oct 6, 2021, at 3:42 PM,
wrote:
Is
testifying as a custodian for a particular company/organization?
Detective
NYPD/FBI
Child Exploitation Human Trafficking Task Force
Office:
From:
Sent: Wednesday, October 6, 2021 3:33 PM
To:
is
>;
)
EFTA00015084

=== Page 2 ===
Cc:
Subject: RE: GM - Witnesses
Thanks so much,
I
I don't have other info on
Here is
current address and number:
From:
Sent: Wednesday, October 6, 2021 2:28 PM
To:
is
>;
Cc:
Subject: [EXTERNAL] Re: GM - Witnesses
Hey guys,
Can you provide us with a little more information on the following witnesses. DOB's would be great or
approximate age but if not maybe who they are, why they are testifying, city or state they are from?
is attached to this email, and she is assisting us with doing all the checks for the witnesses.
Thanks!
1.
Detective
NYPD/FBI
Child Exploitation Human Trafficking Task Force
Office:
From:
Sent: Monday, October 4, 2021 2:45 PM
To:
is
Cc:
Subject: GM - Witnesses
CAUTION! EXTERNAL SENDER
STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide
user ID or password. Suspicious? Please report to this email address: reportphishing@nypd.org
EFTA00015085

=== Page 3 ===
Below is the list of potential testifying witnesses as discussed. Please run rap sheets as discussed. Do you think you
could get them to us by Wednesday or Thursday? Call if you have any questions, thanks!
1.
18.
19.
20.
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:
EFTA00015086


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=== Page 1 ===
From:
To:
Bcc:
Subject: Page 6 Article re Lefcourt Ltr to
Date: Tue, 03 Jun 2008 13:09:50 +0000
Importance: Normal
Attachments: Page_6_Article_re_Lefcourt_Ltr_tc
odf
Here it is.
<<Page 6 Article re Lefcourt Ltr to Acosta.pdf>>
EFTA00014163


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=== Page 1 ===
11/26/21, 6:57 PM
Mail
(NY) (FBI) Outlook
[EXTERNAL EMAIL] - RE: Image/Video file review for Maxwell case
)
Mon 10/19/2020 12:04 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
(NY) (OGA)
Thanks
I'll touch base with
today.
From:
(NY) (FBI)
Sent: Monday, October 19, 2020 10:02 AM
To:
Cc:
(NY) (FBI)
is
(NY) (OGA) (FBI)
Subject: Re: Image/Video file review for Maxwell case
Hi
I was out of the office when you sent this email. I also will be out of the office this full week. I know
and
are both back now but am happy to give you call to discuss logistics, as I will be helping
on this when I'm back.
Thanks,
From:
Sent: Friday, October 16, 2020 4:51 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
(NYPD)
>;
Subject: [EXTERNAL EMAIL] - RE: Image/Video file review for Maxwell case
Following up on this, I'll be working this evening and all weekend, so I'm happy to have a call whenever works for
you in that timeframe. Ideally, I'd like to touch base before Monday so that we can hit the ground running with
the review first thing Monday morning.
Thanks very much,
From:
Sent: Friday, October 16, 2020 1:45 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
(NYPD)
is
is
(USANYS)
Subject: Image/Video file review for Maxwell case
Hi
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
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EFTA00014970

=== Page 2 ===
11/26/21, 6:57 PM
Mail
(NY) (FBI) - Outlook
My supervisors gave me your name as the point of contact at the FBI to help coordinate the review of images and
videos from Jeffrey Epstein's devices for discovery in the Ghislaine Maxwell case. Thank you so much for being
willing to help out with this while
and
are traveling.
I've spoken with
about some of the logistics, and it would be great if you and I could have a call to
talk about next steps. Is there a time this afternoon when you would be free for a call?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
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EFTA00014971


c1: EFTA00016373
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016373.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
SEALED
UNITED STATES OF AMERICA
:
INDICTMENT
:
- V. -
:
20 Cr.
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as young as 14 years old when they were
groomed and abused by MAXWELL and Epstein, both of whom knew
that certain victims were in fact under the age of 18.
2.
As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00016373

=== Page 2 ===
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
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=== Page 3 ===
4.
Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a.
MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b.
Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
C.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
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=== Page 4 ===
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d.
In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e.
Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5.
GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
4
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=== Page 5 ===
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6.
Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a.
A a multi-story private residence on the
Upper East Side of Manhattan, New York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
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=== Page 6 ===
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
C.
A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
6
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=== Page 7 ===
d.
MAXWELL's personal residence in London,
England.
7.
Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
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=== Page 8 ===
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b.
MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
8
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=== Page 9 ===
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
C.
MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8.
In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
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=== Page 10 ===
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
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=== Page 11 ===
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
C.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
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=== Page 12 ===
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
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=== Page 13 ===
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423 (a) .
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423 (a).
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
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=== Page 14 ===
New York Residence, in violation of New York Penal Law, Section
130.55.
C.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
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=== Page 15 ===
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423 (a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you're talking about.
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=== Page 16 ===
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall.
Q.
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A.
No.
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=== Page 17 ===
Q.
Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A.
I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q.
I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A.
That is my testimony, that is correct.
Q.
Is it your testimony that you' ve never given
anybody a massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
Q.
You never gave [Minor Victim-2] a massage is your
testimony?
A.
I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
FOREPERSON
AUDREY STRAUSS
Acting United States Attorney
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=== Page 18 ===
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
INDICTMENT
(18 U.S.C. $$ 371, 1623, 2422, 2423 (a),
and 2)
AUDREY STRAUSS
Acting United States Attorney
Foreperson
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EFTA00016390


