# docs_fts_content

c1: EFTA00015088
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015088.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
10/6/21, 12:59 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 III search from the State of New York based on:
The information in this rap sheet is subject to the following caveats:
Multi-Source - Subject has information maintained by other states or in
multiple NYS files maintained by the FBI available through the
Interstate Identification Index. Refer to FBI Number:
(New
York State Department Of Criminal Justices; 2021-10-06)
Sentencing - Where an individual is sentenced June 1, 1981 or later on
more than one charge within a docket, the sentence may be considered to
be concurrent unless identified as consecutive. (New York State
Department Of Criminal Justices; 2021-10-06)
IDENTIFICATION
1/2
EFTA00015088

=== Page 2 ===
10/6/21, 12:59 PM
III/FBI/State Delayed Response
CRIMINAL HISTORY
Cycle 001
*
*
*
END OF RECORD
*
*
*
2/2
EFTA00015089


c1: EFTA00014889
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014889.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
November 27, 2021
REQUEST TO BE FILED UNDER SEAL
BY EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court's directive at the
November 23, 2021 final pretrial conference that the Government provide its anticipated order of
witnesses for the upcoming trial in the above-referenced matter.¹ Consistent with the Court's
instruction, below is the order of witnesses that the Government currently expects to call during
the first two to three days of trial:
I
1.
2.
(testifying under the pseudonym "Jane")
3.
(testifying under the pseudonym
")
4.
5.
The Government has also attempted to approximate the order in which its remaining
witnesses will testify at trial. The Government notes, however, that this order may change,
I The Government respectfully requests that this letter be filed under seal. Because this letter does
not seek any relief or require any ruling by the Court, it is arguably not a judicial document subject
to the common law presumption of access. Moreover, this letter contains the identities of
witnesses, including witnesses whom the Court has authorized to testify using pseudonyms or their
first names.
EFTA00014889

=== Page 2 ===
Page 2
depending on, among other factors, the pace of trial. Many of the below-listed witnesses will be
traveling from out of state, and many witnesses have personal and/or professional obligations
around which the Government is attempting to schedule. Accordingly, it is possible that the
Government may call some of these witnesses in a different order than that indicated below.
Additionally, the Government reserves the right to call additional witnesses should unexpected
developments arise during trial.
With those understandings, the Government currently expects to call its remaining
witnesses in the following order:
6.
7.
8.
9.
10.
11.
under the pseudonym
3
12.
13.
14.
15.
other (testifying under the pseudonym
"2)
16.
17.
fying only under his first name,
")
18.
19.
20.
lifying only under her first name,
")
21.
22.
stifying only under her first name,
")
23.
r
24.
25.
26.
27.
lifying under her full name,
")
28.
29.
30.
2 The Government previously indicated that this witness would testify under the pseudonym
"John." Because defense counsel expressed concerns about confusion that could arise from that
name, the Government has changed this pseudonym to
"
EFTA00014890

=== Page 3 ===
Page 3
31
Finally, the Government notes that it may elect not to call some of the above-listed
witnesses as trial progresses. The Government will promptly inform the Court and defense counsel
if it determines that any witness will not be called in the Government's case-in-chief.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (by email)
EFTA00014891


c1: EFTA00016130
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016130.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
To
C
Subject: RE: US V. Gatto - Oath Inc. Motion to Intervene
Date: Fri, 02 Aug 2019 15:22:13 +0000
Attachments: Brown_v_Maxwell.doc
Dear Counsel: Would you please let me know if you have any objection to my filing with the Court a copy of the attached
decision of the Second Circuit in Brown V. Maxwell (July 3, 2019)? Thank you, and have a good weekend. Jon
Jonathan M. Albano
Morgan, Lewis & Bockius LLP
One Federal Street I Boston. MA 02110-1726
www.morganlewis.com
Assistant: Kathleen A. Slowe
I
I
From:
Sent: Monday, July 22, 2019 5:17 PM
To: Albano, Jonathan M
; Peng, Victoria
; Steve
Haney
; Schachter, Michael
Moore, Mark
C.
Cc:
is
;
(USANYS)
Subject: US V. Gatto - Oath Inc. Motion to Intervene
[EXTERNAL EMAIL]
Counsel,
Please find attached the Government's opposition to Oath Inc.'s motion to intervene for the limited purpose of obtaining
materials. An unredacted version of this filing is being provided to the Court on an ex parte basis.
Best
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, NY 10007
EFTA00016130

=== Page 2 ===
DISCLAIMER
This e-mail message is intended only for the personal use
of the recipient(s) named above. This message may be an
attorney-client communication and as such privileged and
confidential and/or it may include attorney work product.
If you are not an intended recipient, you may not review,
copy or distribute this message. If you have received this
communication in error, please notify us immediately by
e-mail and delete the original message.
EFTA00016131


c1: EFTA00015025
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015025.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Epstein
Start Date: 2020-02-04 22:30:00 +0000
End Date: 2020-02-04 23:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2020-02-04 00:54:08 +0000
Date Modified: 2020-02-04 00:54:08 +0000
Priority: 5
DTSTAMP: 2020-02-04 00:40:11 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00015025


c1: EFTA00016923
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016923.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted:
proffer (re abuse)
Start Date: 2019-12-04 19:00:00 +0000
End Date: 2019-12-04 22:00:00 +0000
Location: Winston & Strawn offices,
Class: X-PERSONAL
Comment:
Date Created: 2019-11-27 17:56:10 +0000
Date Modified: 2019-11-27 17:56:10 +0000
Priority: 5
DTSTAMP: 2019-11-27 16:46:04 +0000
Attendee:
EFTA00016923


c1: EFTA00015836
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015836.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(ODAG)"
,
(USANYS)"
Subject: Call on Epstein/Maxwell Documents
Date: Wed, 22 Jul 2020 20:06:06 +0000
Importance: Normal
Attachments: unnamed
EFTA00015836


c1: EFTA00014900
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014900.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: United States V. Ghislaine Maxwell --
lopens
Date: Mon, 29 Nov 2021 14:33:24 +0000
Good luck ladies! I have no doubt you will rock it.
From:
Sent: Sunday, November 28, 2021 9:59 AM
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 --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00014900


c1: EFTA00014572
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014572.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
2
Reisepaß Nr.
Passeport N°
Passport Nr.
Familienname
Nom
FORTELNI
Surname
Vorname
Prénom
Christian name
Marius Robert
Datum und Ort der Geburt
Date et lieu de naissance
Date and place of birth
Beruf
Profession
Profession
Manager
Wohnort
Domicile
Residence
Staatsbürgerschaft
Nationalité
ÖSTERREICH / AUTRICHE / AUSTRIA
Nationality
PERSONSBESCHREIBUNG
SIGNALEMENT
DESCRIPTION OF BEARER
Größe
Taille
Height
1.84m
Farbe der Augen
Couleur des yeux
Colour of eyes
braun
Besondere Kennzeichen
Signes particuliers
stempel
Distinguishing marks
keine
Hill Unterschrift des Inhabers
Signature du titulaire
3
Signature of bearer


c1: EFTA00015753
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015753.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
To:
)"
>, 'Laura Menninger'
<lmenninger@hmflaw.com>,
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Thu, 08 Apr 2021 21:22:13 +0000
Inline-Images: image001.jpg
Thanks,
11am is fine. I don't think we will need more time. If for some reason we need to go back later in the
week, we can arrange for another trip to finish up.
From:
)
[mailto:
Sent: Thursday, April 08, 2021 5:19 PM
To: Christian Everdell; 'Laura Menninger';
);
(USANYS)
Cc: Jeff Pagliuca; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Chris,
I am going to be tied up for a bit the morning on the 12th. Would it work on your end to meet at the warehouse at 11am,
please? The warehouse will be open until 4:30pm, though I'm told I can request additional time in advance if you think
the review will take more than 5 ½ hours.
Also, I am working on gathering information in response to Laura's email and expect to be able to respond to it later this
evening.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, April 8, 2021 5:06 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00015753

=== Page 2 ===
-
I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work?
Thanks,
Chris
From: Laura Menninger [mailto:Imenninger@hmflaw.com]
Sent: Wednesday, April 07, 2021 4:23 PM
To:
)';
);
(USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
EFTA00015754

=== Page 3 ===
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
)
is
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
EFTA00015755

=== Page 4 ===
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
EFTA00015756

=== Page 5 ===
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
EFTA00015757

=== Page 6 ===
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00015758

=== Page 7 ===
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
EFTA00015759

=== Page 8 ===
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
EFTA00015760

=== Page 9 ===
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
EFTA00015761

=== Page 10 ===
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00015762

=== Page 11 ===
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
EFTA00015763

=== Page 12 ===
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00015764

=== Page 13 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
)
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
EFTA00015765

=== Page 14 ===
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00015766

=== Page 15 ===
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
EFTA00015767

=== Page 16 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
)
is
)
is
(USANYS)
EFTA00015768

=== Page 17 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00015769


c1: EFTA00016924
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016924.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
,
)
]"
Cc:
)"
,
)"
Subject: FW: 302s, photos, &
Proffer notes
Date: Wed, 27 Nov 2019 18:43:07 +0000
Attachments: Proffer of
Interview_231.pdf;
pdf; Photos provided by
7.31.19.pdf;
.pdf;
pdf
Hi
when you can, could you please save these in the Epstein witness folder with
file naming
convention? Thanks!
Original Message
From:
)
Sent: Wednesday, November 27, 2019 11:46 AM
To:
)
i
;
Cc:
Subject: 302s, photos, &
Proffer notes
Hi all,
See attached.
Thanks,
EFTA00016924


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: NT 3500
Date: Sun, 11 Apr 2021 06:48:41 +0000
All of these edits have now been made.
From:
Sent: Sunday, April 11, 2021 12:21 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: NT 3500
Last email on this I think! Final notes from me-I'm going to take a look at one or two things tomorrow morning, but
otherwise I'm done:
For
please remove the full SDNY GJ transcript (leave
any SDFL grand jury stuff, please). Instead, I'm going to send you excerpts to go in each folder.
For the
folder: please move that one item to the withhold folder of the
folder and
delete the
folder.
Please delete the folders for
For the
folder, please move the file marked Guardian Information to the
folder and
otherwise delete the
folder
Please move the contents of the
folder to the
folder and delete the
folder
Please move
to the not-a-witness folder
Thanks!
From:
Sent: Saturday, April 10, 2021 1:47 PM
To:
(USANYS) [Contractor]
Cc:
)
is
(USANYS)
Subject: RE: NT 3500
Hi
Some additional notes:
-The
folder can just be moved to the not-a-witness folder
-The
folder contains nothing to be produced - can you move all that stuff to the do not produce folder
within the
folder and delete the witness folder for
who is not a witness?
-The
folder contains one item. Please move that to the
folder and delete the folder for
-Could you please move the
folder to the potential testifying witness folder, and if possible could you
please ask an intern to do a rough transcript of the recording?
EFTA00015831

=== Page 2 ===
-For the
folder, please move that one item to the
folder and delete the
folder
Thanks!
From:
Sent: Saturday, April 10, 2021 12:33 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: NT 3500
Hi
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
EFTA00015832


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=== Page 1 ===
From:
(USANYS)"
To: "Williams, Damian (USANYS)
Subject: Re: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 12:15:14 +0000
Thanks so much Damian.
On Nov 29, 2021, at 6:48 AM, Williams, Damian (USANYS)
wrote:
Good luck this morning. You'll be fantastic.
Begin forwarded message:
From
Date: November 28, 2021 at 9:59:11 AM EST
To:
Cc:
Subject: United States V. Ghislaine Maxwell -
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took
place in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions
and opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00015335

=== Page 2 ===
EFTA00015336


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=== Page 1 ===
WARNING: ADDITION OR MUTILATION OF ENTRIES PASSPORT IS PROHIBITED. INVALID.
ALTERATION, ANY UNOFFICIAL CHANGE WILL RENDER THIS
NAME-NOM JEFFREY EDWARD EPSTEIN
SEX-SEXE
BIRTHPLACE-
M
ISSUE DATE-DATE DE DELIVRANCE
BIRTH
FEB. 27, 1985
EXPIRES ON-EXPIRE LE
NATIONALITY-NATIONALITÉ
UNITED STATES OF AMERICA
FEB. 26, 1995
n SIGNATURE OF R BEARER-SIGNATURE DU TITULAIRE
NOT VALID UNTIL SIGNED
ATTACHED
AMERICA


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=== Page 1 ===
From:
Subject: FW:
Fan Club Request
Date: Tue, 30 Nov 2021 12:44:56 +0000
Attachments: 2021.11.29_Openings,_Visoski_(public).PDF
fan club is requesting a transcript of the opening. Can you please let me know whether it's okay to send Martin the
public transcript from yesterday, attached?
From:
Sent: Tuesday, November 30, 2021 1:37 AM
To:
Subject: [EXTERNAL]
Fan Club Request
Hope you're doing well. I am having a good time although I miss you and the Office, and I am still trying to figure out
what to do with my brunches now that Heights Café / Giulia's is for-real gone.
I have a special request. I am a massive
fan, having done the
retrial with her back in the
day. And my partner and former Office guy
is one of her mentors and counts himself a massive fan also. We
weren't able to be there for the opening yesterday. We'd love a transcript. Can you get us one?
Thanks,
m
Martin S. Bell (bio)
Simpson Thacher & Bartlett LLP
EFTA00014907


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=== Page 1 ===
From:
)"
To: Gloria Allred
Cc:
)"
)"
Subject: RE: Call this week
Date: Wed, 01 Apr 2020 02:16:45 +0000
Inline-Images: image001.png; image002.png
Gloria,
That works for us, thank you, and we can all use the same conference line as we did earlier today:
Dial-in:
Code: 933571
thanks,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 19:24
To:
Cc:
is
Subject: RE: Call this week
I explained what you shared with me with
She would like to speak with you directly. Would you be available
for a conference call with her and me tomorrow at 4P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbl
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 11:46 AM
EFTA00016220

=== Page 2 ===
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria, we do need to use a conference line after all - if you could please dial in at:
Dial-in:
Code: 933571
And I'll send an Outlook meeting invite as well, in case that's helpful, and we'll speak with you in 15 minutes. Thank you
again.
From: Gloria Allred
Sent: Tuesday, March 31, 2020 14:11
To:
Subject: RE: Call this week
I will. Thanks.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 11:08 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Please call my cell at
(If we end up needing a conference line I'll send that before 3:00 EST as well.)
thanks,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:54
To:
EFTA00016221

=== Page 3 ===
Cc:
is
Subject: RE: Call this week
That works. Please advise as to which number I should call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best
Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:51 AM
To: Gloria Allred
Cc:
)
is
Subject: RE: Call this week
Yes, if that works for you - so in a little more than an hour. Or let us know if there's a different preferable time.
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:50
To:
Cc:
)
is
)
Subject: RE: Call this week
3P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
EFTA00016222

=== Page 4 ===
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National
Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:46 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
That would be great, thanks. Would 3:00 work for you? Or please let us know if
more convenient time, we can
be flexible.
thanks again,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:31
To:
Cc:
>;
)
Subject: RE: Call this week
May I call you with an update? What time today are you available for a call?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:03 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
EFTA00016223

=== Page 5 ===
Gloria,
We were wondering if you or your colleagues have been able to reach any of the clients we discussed last week? It would
be very helpful to know their views and reactions shortly - and we're of course happy to speak with them directly as well
if that would be helpful.
thanks,
From:
Sent: Thursday, March 26, 2020 15:45
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Gloria,
Thanks for speaking with us just now. The individuals we mentioned are
Thanks,
Sent from my iPhone
On Mar 26, 2020, at 10:16 AM, Gloria Allred
wrote:
Thank you.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Thursday, March 26, 2020 7:12 AM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
We can use the below conference line:
Dial-in:
Code: 933571
EFTA00016224

=== Page 6 ===
Thank you,
On Mar 25, 2020, at 8:55 PM, Gloria Allred
> wrote:
I would be happy to send a Zoom number to you or feel free to send me a conference number to call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National
Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 5:53 PM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Thanks very much. 3pm EST works for us. What number should we call?
Best,
On Mar 25, 2020, at 8:21 PM, Gloria Allred
wrote:
Yes. What time tomorrow is better for you, 3 P.M. e.s.t. or 4P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National
Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 1:55 PM
To: Gloria Allred
EFTA00016225

=== Page 7 ===
Cc:
is
Subject: Call this week
Gloria,
Would you have time for a call with the SDNY Epstein team tomorrow or Friday? We would like to provide you with a
bit of an update and discuss some of your clients in particular.
Hope you are staying safe and healthy.
Best,
Assistant United States Attorney
Southern District of New York
1 St.
Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
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
EFTA00016226

=== Page 8 ===
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.
EFTA00016227


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=== Page 1 ===
From:
To:
Subject: RE: case records scanning
Date: Mon, 19 Oct 2020 03:34:34 +0000
Thank you
From:
Sent: Sunday October 18 2020 PM
To:
Subject: RE: case records scanning
Okay.
From:
Sent: Sunday, October 18, 2020 20:04
To:
Subject: RE: case records scanning
Thanks
I never heard back from
after your most recent email to him about an index. If you wouldn't mind
following up, I'd be grateful. l'll follow up with
on the boxes.
From:
Sent: Sunday, October 18, 2020 7:11 PM
To:
Subject: RE: case records scanning
I'm not sure if this is directed to me specifically, but I don't have any additional information since last week - did you guys
hear back from
after my email of 10/12 at 12:16? He was who I asked about the index from the vendor project. The
other pending question is whether there are discs in the boxes themselves - if not, then I think it's a safe inference that all
the discs in the boxes were extracted by the vendor, since they'd be reflected in the DVDs.
I think
was going to check on the second half of that when she got back this coming week, and let me know if you
want me to ping
on my email from Monday.
From
Sent: Thursday, October 15, 2020 19:09
To:
Cc:
Subject: RE: case records scanning
I found the discs and was able to match up some of them as containing the contents of discs whose labels were scanned
into Relativity. But there are several that I cannot match up with the "CANNOT BE SCANNED" sheets on Relativity (this is
primarily because several of the "CANNOT BE SCANED" sheets just say "1 CD" or "3 CDs" without any way of identifying
what is on the unscanned CD).
Is there a way to know which of these CDs were loaded onto Relativity and which were not? Any luck finding the index?
From:
Sent: Monday, October 12, 2020 4:30 PM
To:
Cc:
Subject: RE: case records scanning
Of course, no problem. And the discs are in the hard copy Epstein "file," which consists of three redwelds on the shelves
behind where
used to sit.
was the keeper of them previously, and then he turned them over to
)
A couple things to note on the discs themselves - first, there are two sets, so don't be surprised when there are many
more than 55 total. And second, that number is approximate - I don't think I had personally counted them when I sent
the email to
and also there are substantive discs and load file discs. But it was around that number, and in any
EFTA00015211

=== Page 2 ===
event, they're all on that shelf. And hopefully
will be able to send, or point you toward, an index for those materials
from the vendor we had unitize them.
From:
Sent: Monday, October 12, 2020 16:17
To:
Cc:
Subject: RE: case records scanning
Thanks very much for working through this,
I'm planning to be in the office tomorrow and would like to lay eyes on
the 55 discs we have so I know what we're talking about. Where would I find them?
From:
Sent: Monday, October 12, 2020 12:46 PM
To:
Cc:
Subject: FW: case records scanning
I actually found the answers to some of this morning's questions. They're a few emails below (but I'm including the chain
for context). The answer from
on the discs-the highlights below are her responses; you guys should have that
email in your records as well-is that they did not extract the contents of the discs that were "scattered throughout" the
boxes. They made copies of them, like actual digital copies, but did not extract them onto the DVDs that were the "scans"
of the boxes. So those discs will still need to be extracted / uploaded to be reviewed.
The one wrinkle on those discs is, keep in mind that we sent all the discs that
gave us to be unitized and uploaded
to Relativity by our own vendor. So if it happens to be that what we sent to our vendor was (1) a bunch of discs that
included scanned hard copies, and (2) some discs that were just copies of discs, our vendor may actually have solved this
problem for us. I think the way to check that is to ask
how those four-set-discs were labeled, and also to ask
if there are any discs still in the boxes (if not, we've already had them scanned and uploaded to Relativity). I should
say, I have something due tomorrow so I'm in the office, so I just looked at the discs themselves, and to me there's no
obvious way to check this on what we have - e.g., no discs are marked "1 of 4".
I also asked at the time about any images that were not scanned, and she said at the time she would check on those and
get back to us. She never did. The context to that is, I think, that this was all in mid- and late-July 2019. There then were a
number of technical issues on getting the data from the DVDs sent by the FBI uploaded to Relativity, which went into the
first week or so of August. And then of course on August 10, our world changed, and we were no longer doing discovery.
In any event, l'll email
now on two questions: First, the discs that we supposedly received four copies of, how were
they labeled (and are they included in the approximately 55 discs we received back, or were they put into the boxes with
the hard copy files)? And second, the question of any hard copy documents they didn't scan. (And will also email
and
to see where the boxes physically are now.)
Obviously I don't have a vote, but personally, unless FBI did some very specific notations in the originals that are easily
accessible, it's just 23 boxes - we could, and should, just send those boxes to a vendor now. They'd be back in your hands
in a week or two, and you'd actually have everything you need.
From:
Sent: Tuesday, July 16, 2019 05:07
To
Cc:
Subject: RE: case records scanning
Everything is going out via fedex today. It will be sent to FBI New York (discs and boxes) to
attention.
Once I have the tracking numbers I will provide them to you.
From:
Sent: Monday, July 15, 2019 8:08 PM
To:
Co
Subject: RE: case records scanning
EFTA00015212

=== Page 3 ===
This all makes sense, thanks very much. Please let us know when the discs are sent? And I guess also when the hard copy
docs are sent (and whether you were able to locate the images that were not scanned). Thanks again.
From:
Sent: Monday, July 15, 2019 04:10
To
Cc:
Subject: RE: case records scanning
Please see my responses below.
From:
Sent: Saturday, July 13, 2019 3:56 PM
To
Cc:
Subject: RE: case records scanning
That's great, thanks very much for all your and your team's work and for the update. That makes sense regarding the 1As,
thanks.
With respect to the images that were not scanned, is there any way to flag them in the original hard copies somehow, so
that we can easily find them and refer to them when the hard copy documents are sent back to New York? Just to avoid
needing to try to flip through all the original documents to find them. Let me check and see if a notation was made as to
where these images were located or if I can readily/easily find them in output.
Regarding the discs, I'm not sure I totally understand - when you say four copies each, were there just four discs total? Or
possibly I'm just misunderstanding the explanation. And related, is it right that those discs were not processed (just
copied) so we'll need to look at those separate for our review? Sorry I should have been clearer. We just copied the discs
not processed and made four copies each which is our standard. The thought being when we burn output we always give
a complete set that in theory would go to the defense, AUSA, and two copies to the Agent (one for him/and a back-up).
The discs we found in the files contain pdfs (searchable), jpgs, gifs, and tif files
And final question is just how all the scanned materials will be transmitted, so we can plan how most efficiently to receive
them and get them processed here. We will send everything back to you on dvds.
thanks again,
From:
Sent: Friday, July 12, 2019 13:59
To:
Cc:
Subject: RE: case records scanning
Good Afternoon!
Here is the latest. We have finished scanning!
In the course of going through the paper it was discovered that at some point in time (perhaps between 2013 and 2015
when it was last digitized) three 1As failed to make it back into their respective file jackets. It's not clear what happened or
who is at fault. I can tell you that we were able to conduct a search of our local network and retrieve the images. I spoke
with our Field Evidence Unit who recommended that prior to inserting the images we create a cover sheet that reflected
that the images were not a part of the "original" paper rather they were regenerated from a digital copy. The 1As in
questions are 1A10, 1A28, 1A84 as well as two missing serials in 31E-MM-108062-GJ SEC 001 SER 1-45. My digital team is
addressing this matter and has assured me I'll be able to burn the output first thing Monday so that we can get everything
returned to you.
A few other items to point out. There were some pornographic images of young girls. These were not imaged per our
protocols. You As you review the content anywhere these images may have been you will see a DocLab kicksheet that
states "possible child pornography" DO NOT SCAN. The original documents are still in their original location - they were
just not scanned.
EFTA00015213

=== Page 4 ===
Finally, there were a number of discs scattered throughout. We made physical copies - one for one ratio of each (four
copies each) to go along with the physical paper scanned. These will be sent along with the discs we will generate.
Please let me know if you have any questions. I'll be in bright and early Monday morning.
From:
Sent: Tuesday, July 09, 2019 11:13 PM
To:
C
Subject: RE: case records scanning
Thanks very much for letting us know, that's extremely helpful and we appreciate it! Looking forward to being in touch as
it continues, and thanks again.
From:
Sent: Tuesday, July 09, 2019 15:55
To:
Cc:
Subject: RE: case records scanning
Gentlemen:
I just wanted to give you a quick update.
We finished inventorying all 22 boxes and released everything to DocLab last evening for scanning. As of this writing we
are looking good for meeting the original deadline - give or take a day. We still have a few things to tweak, but I'm
confident that things are looking good and we'll have this wrapped up within the next day or two. I'll send you a more
detailed email tomorrow morning when I get in.
Take care and have a good evening.
From:
Sent: Wednesday, July 03, 2019 11:16 AM
To:
Cc:
Subject: RE: case records scanning
Thanks very much for the update - I think unless you guys can confirm that any prior scans were absolutely 100% done
correctly (and separated by document, etc.), we'd prefer to have them just done in one full set now-particularly knowing
that this will all be the subject of discovery, which definitely wouldn't have been the case in 2013.
thanks again,
From:
Sent: Wednesday, July 03, 2019 11:10
To:
Cc:
(
Subject: RE: case records scanning
Happy 4th of July Eve. We just received 22 boxes about 5 minutes ago. We discovered that the Miami Field Office had
requested DocLab to scan a number of them back in 2013. I'm hoping (fingers crossed) that the images are available on
our internal network so that I can access them and just simply reprocess the digital output, if not we'll re-prep and scan
accordingly. We will keep you posted.
Take care and have a great holiday.
EFTA00015214

=== Page 5 ===
From:
Sent: Tuesday, July 02. 2019 2:10 PM
To:
Co
Subject: RE: case records scanning
We're under time pressure but I think the most important thing is that your folks have the time you need to do the job in
a way you're comfortable with-being able to scan each document separately, dealing with any random scraps of paper,
post-its, etc etc. If doing the best possible job requires an extra few days that's totally understandable, especially given the
holiday. Thanks again for the focus on it, and for following up.
From:
Sent: Tuesday. July 02. 2019 14:06
To:
Cc:
Subject: RE: case records scanning
I got the scan request thanks.
How much wiggle room can I get on the deadline we originally talked about of 7/10? I'm concerned that with the boxes
going from 15 to 22 and now not showing up until sometime tomorrow and Thursday a holiday the 10th is going to be
extremely tight. Can I extend out at all to the 16th? If not I understand and we'll work to make it work somehow.
From:
Sent: Tuesday, July 02, 2019 10:39 AM
To:
Cc:
Subject: RE: case records scanning
My apologies, appartently with a Fedex pickup this size an appointment had to be setup. The pickup was scheduled for
today and will arrive in VA tomorrow, tracking number 4744 7647 0418.
Thanks,
Squad C-20
VCAC/Human Trafficking
FBI New York
office
mobile
From:
Sent: Monday, July 01, 2019 10:46 PM
To:
Cc:
Subject: RE: case records scanning
Quickly following up on this, can we confirm the boxes went out last week?
From:
Sent: Monday, July 01, 2019 11:23
To:
Cc:
Subject: RE: case records scanning
I just want to follow-up that the boxes were shipped. Fedex is not showing anything in-bound for us today.
From:
Sent: Friday, June 28, 2019 12:02 PM
To:
EFTA00015215

=== Page 6 ===
Cc:
Subject: RE: case records scanning
The boxes will be shipped via Fedex this afternoon.
From
Sent: Friday, June 28, 2019 8:28 AM
To
Cc
Subject: RE: case records scanning
Let me know as soon as the boxes ship. Thanks!
From
Sent: Thursday, June 27, 2019 2:16 PM
To
Cc:
Subject: RE: case records scanning
Thanks very much for chatting earlier today, and as promised wanted to send an email so you have our full contact info.
My colleague
and I are the prosecutors working on the investigation - she's also copied here, and we're
available anytime via email, or by phone at:
(office),
(cell)
(office),
cell)
It's our understanding that there are approximately 23 boxes of papers, give or take, and that they include approximately
two boxes from FBI case file 72-MM-113327 and the remainder from FBI case file 31E-MM-108062. Please don't hesitate
to reach out if anything comes up at all, or if we can be of any help, and thanks very much for putting this at the top of
your list, we really appreciate it.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00015216


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=== Page 1 ===
From:
)"
To: Jack Scarola
Cc:
)"
(USANYS)"
Subject: RE: 12/04/09
VS Epstein Deposition Transcript
Date: Thu, 10 Sep 2020 15:30:16 +0000
Jack,
Thanks for your email. We will likely reach out to your adversary in the deposition to ask for a copy, but I wanted to check
to see whether you had already done so.
Thanks,
From: Jack Scarola
Sent: Wednesday, September 9, 2020 9:53 AM
To:
is
is
(USANYS)
Subject: Fwd: 12/04/09
VS Epstein Deposition Transcript
The email exchange below confirms our inability to locate the first volume of
deposition. However, attached are
fairly detailed notes of Paralegal/Investigator
who attended the deposition and recorded these notes
contemporaneously.
appears to have held nothing back, and the notes certainly paint a picture of the kind of
troubled young women who were particularly susceptible to Epstein's pattern of recruitment, grooming and
victimization.
Sent from my iPad
Begin forwarded message:
From: "Chris R. Rodgers"
Date: September 8, 2020 at 3:30:51 PM EDT
To: Jack Scarola
Cc: Mary McCann
"Wendy P. Calvet"
"cmavsepsteinetalz6385257@projects.filevine.com" <cmavsepsteinetalz6385257@projects.filevine.com>
Subject: FW: 12/04/09
vs Epstein Deposition Transcript
Jack, below is the "Unable to locate" response from Prose Court Reporting. Visual Evidence, the videography
service used, also confirmed on Friday that a copy of the video is no longer available. I have attached
notes from that deposition.
From: toni proseflorida.com
Sent: September 7, 2020 7:03 AM
To: Chris R. Rodgers
Subject: RE: 12/04/09
vs Epstein Deposition Transcript
Chris,
EFTA00016304

=== Page 2 ===
I have searched our records and archives and I am unable to locate Volume I of this deposition from
2009.
Sincerely,
Toni
Privileged and Confidential I Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is
not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00016305


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=== Page 1 ===
From:
To:
)"
Cc:
(USANYS)"
)"
Subject: RE: Items to Reproduce
Date: Fri, 18 Dec 2020 18:52:43 +0000
Attachments: 2020.12.18_MDC - Maxwell_MAIN.pdf; 2020.12.18 MDC - Maxwell_PASSWORD.pdf
Here are the two cover letters for MDC, as well - thank you!
From:
Sent: Friday, December 18, 2020 12:57 PM
To:
Cc:
(USANYS)
is
is
Subject: Re: Items to Reproduce
Thanks you so much for catching that, letting us know, and fixing it so quickly,
Really appreciate that. Please just
let me know when the reproductions are ready to go, and l'll email defense counsel and the MDC.
On Dec 18, 2020, at 11:36 AM,
wrote:
Hi all,
I was updating the discovery index for Maxwell and unfortunately realized that seven items (two items from the 7th
Production, located here; and all five PDFs from the 8th Production, located here) will have to be reproduced, as their
Bates numbers were slightly incorrect (missing a digit in the middle of the bates number). I can re-stamp and update
them in the shared momentarily - but my apologies that we're just now catching this!
The seven reproduced items will consist of one Excel file and six PDFs, so they'll be small enough to email to defense
counsel and small enough to put on a disc to send to Maxwell at MDC. I can draft a cover letter detailing the reproduced
items and their updated Bates ranges, and since I'm in the office today I can send the disc out to MDC this afternoon.
Thanks so much for your understanding!
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016765


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=== Page 1 ===
2996479 CCA
AT&T
11760 US HWY 1, SUITE 300
NORTH PALM BEACH FL 33408
(Fax)
CERTIFICATE OF AUTHENTICITY OF DOMESTIC RECORDS PURSUANT TO
FEDERAL RULES OF EVIDENCE 902(11) AND 902(13)
I, Christine Carson, attest, under penalties of perjury by the laws of the United States of America
pursuant to 28 U.S.C. § 1746, that the information contained in this certification is true and
correct. I am employed by AT&T, and my title is Legal Compliance Analyst. I am qualified to
authenticate the records attached hereto because I am familiar with how the records were created,
managed, stored, and retrieved. I state that the records attached hereto are true duplicates of the
original records in the custody of AT&T. I further state that:
a. All records attached to this certificate were made at or near the time of the occurrence of
the matter set forth by, or from information transmitted by, a person with knowledge of
those matters, they were kept in the ordinary course of the regularly conducted business
activity of AT&T, and they were made by AT&T as a regular practice; and
b. Such records were generated by AT&T's electronic process or system that produces an
accurate result, to wit:
1.
The records were copied from electronic device(s), storage medium(s), or file(s)
in the custody of AT&T in a manner to ensure that they are true duplicates of the
original records; and
2.
The process or system is regularly verified by AT&T, and at all times pertinent to
the records certified here the process and system functioned properly and
normally.
I further state that this certification is intended to satisfy Rules 902(11) and 902(13) of the
Federal Rules of Evidence.
June 17, 2020
Christine Carson
Date
Signature
EFTA00017125

=== Page 2 ===
06/15/2020 22:51
2123848289
C20
PAGE 02/04
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
AT&T Wireless
Legal Compliance
11760 Highway 1, Suite 600
North Palm Beach, FL 33408
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:
July 6, 2020
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of
18 U.S.C. §§ 1591, 1594(c), 2423(a), 2422(b)
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
Child Exploitation and Human Trafficking Task Force, telephone:
or via email at anyoung2@fbi.gov; and (2) accompanied by an executed copy of the
attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF
POSSIBLE.
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
June 15, 2020
GEOFFREY BERMAN
United States Attorney for the
Southern District of New York
Assistant United States Attorney
DISTRICT STATE UNITED COURT POR MOR THE LOWER
One St. Andrew's Plaza
New York, New York 10007
OPNEW
Telephone:
EFTA00017126

=== Page 3 ===
06/15/2020 22:51 2123848289
C20
PAGE 03/04
RIDER
(Grand Jury Subpoena to AT&T, dated June 15, 2020)
Please provide any and all records (including, but not limited to, incoming and outgoing
calls with any call details, local and long distance usage details, all subscriber opening and/or
registration documents, all subscriber identification and contact information, all subscriber
billing and payment information, SMS/text messaging records, IP history and login records,
associated email addresses and/or screen names, and any additional accounts associated with any
of the below-listed names, identifiers, addresses, phone numbers, and accounts listed and
associated records for those accounts) relating to the following telephone numbers, as listed
below, for the time period of March 1, 2020 to the present:
N.B.: Personal appearance is not required if the requested records are (1) produced by on
or before the return date to Special Agent
Child Exploitation and Human
Trafficking Task Force, telephone:
or via email at
and
(2) accompanied by an executed copy of the attached Declaration of Custodian of Records.
PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
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.
EFTA00017127


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=== Page 1 ===
JANE DOE #5
(
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 53
11/17/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 58
12/5/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 61
12/13/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 65
12/14/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 69
12/18/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 72
12/23/04
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 74
1/1/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 81
1/8/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 82
1/9/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 88
1/26/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 91
2/1/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 98
2/10/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 107
2/25/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 108
3/1/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 111
3/16/05
Conspiracy to entice a minor to
engage in prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 3
JANE DOE #5
EFTA00016013

=== Page 2 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 115
3/21/05
Conspiracy to entice a minor to
engage in prostitution
Ct. 9
11/14/04 -
EPSTEIN
Enticement of a minor to engage in
3/29/05
prostitution
Ct. 30
11/18/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 31
12/3/04
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 32
12/13/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 34
1/1/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 37
2/3/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 38
2/10/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 39
2/21/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 2 OF 3
JANE DOE #5
EFTA00016014

=== Page 3 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
Ct. 41
3/4/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 42
3/18/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 53
11/14/04 -
EPSTEIN
Recruiting, enticing, providing, or
3/29/05
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 #5
EFTA00016015


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=== Page 1 ===
FROM
-
28 July 2019
Victim/Witness Coordinator
United States Attorney's Office
One St. Andrew's Plaza
New York, New York 10007
Re: United States vs. Jeffrey Epstein [19 Cr. 490 (RMB)]
Dear Ms.
Enclosed, please find a photograph I believe may be of Jeffrey Epstein with an underage female.
I took the photo across from St. Patrick's Cathedral, on the same corner as the couple. I took the
photo because the woman seemed to be underage and seemed romantically linked to the older man.
The pair were walking closely together -he was holding a small Victoria's Secret boutique bag in his
hand. I was concerned for the well-being of the girl. To me, she seemed to be between fourteen and
sixteen years of age.
At the time I took the photo, I had not heard of Jeffrey Epstein. On the following Monday, I read
about Mr. Epstein's arrest. I am submitting it for your own analysis and review.
The photo was taken on the corner of E51st St and 5th Ave at Olympic Tower on 7 June 2019 at
6:46PM.
I hope it may be of help -also in ending trafficking and abuse, especially as pertains to minors. I
apologise for the delay in submitting it - I was unsure of where to send it.
Sincerely,
M. Rachel Zabala
EFTA00016800

=== Page 2 ===
ALLSAINTS
X

=== Page 3 ===
ALLSAINTS


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=== Page 1 ===
From:
To:
Subject: FW: 19cr490
Date: Wed, 17 Jul 2019 00:54:12 +0000
Importance: Normal
FYI all, this was sent from chambers to defense counsel a short while ago. The relevant provision of their letter reads:
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 appropriate New Mexico official, Detective
,
when he spent any time at his residence there. (The underlying documents are available upon
request.)
Perhaps the issue of bail turns entirely upon whether the defendant notified New Mexico when he was in the state!
From:
Sent: Tuesday, July 16, 2019 20:01
To:
Cc:
Subject: 19cr490
Please provide by noon tomorrow all the underlying New Mexico documents, including applications and
requests, referenced on pp. 6-7 of your July 16, 2019, letter.
EFTA00014480


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: travel approval request
Date: Thu, 07 Nov 2019 19:18:03 +0000
Hi
Would you mind booking my travel arrangements for this trip as well, please? I won't need a hotel, but I'd like to book the
following flights:
Outbound flight: 11/14, JetBlue, 8 a.m. departure from JFK, arriving at LAX at 11:16 a.m.
Inbound flight: 11/14, JetBlue, 8:30 p.m. departure from LAX, arriving at JFK at 4:44 a.m.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, November 6, 2019 6:18 PM
To:
Cc:
is
Subject: FW: travel approval request
Hi
In connection with this trip next week, could you possibly book my travel arrangements, please? That would be a big help,
and thanks in advance. Here's what I had in mind:
Hotel: Doubletree, 1707 Fourth Street, Santa Monica, CA. Checking in on 11/13, checking out 11/14.
We won't need a conference room at the hotel for this trip.
Outbound flight: 11/13, JetBlue, 2:29 p.m. departure from JFK, arriving at LAX at 5:44 p.m.
Inbound flight: 11/14, JetBlue, 8:30 p.m. departure from LAX, arriving at JFK at 4:44 a.m.
My JetBlue frequent flier number is
Thanks,
EFTA00015915

=== Page 2 ===
From:
Sent: Tuesday, November 5, 2019 4:58 PM
To:
Cc:
is
i
is
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Nov 5, 2019, at 4:56 PM,
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
)
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
>;
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
-
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
EFTA00015916

=== Page 3 ===
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
)
Sent: Friday, May 24, 2019 14:57
To:
Cc:
>;
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
EFTA00015917

=== Page 4 ===
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00015918


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=== Page 1 ===
From:
To:
Subject: FW: CONFIDENTIAL
Date: Sun, 07 Jul 2019 00:37:35 +0000
Importance: Normal
From: Martin G. Weinberg
Sent: Saturday, July 6, 2019 8:31 PM
To:
Cc: 'Martin Weinberg'
Subject: CONFIDENTIAL
please send a copy of the sealed Indictment of Mr. Epstein to this email address. I will maintain its
confidentiality.
I would also request a copy of any Warrant that has or will be issued to search Mr. Epstein's residence or property and at
the conclusion of any such search the Inventory/s. As I stated, he has been actively legally represented by myself and a
number of other attorneys so to the extent there are any seizures of documents, electronic devices, computers, phones I
would request again that there be no review of their contents until we can discuss meaningful ways to protect the
privileged communications that such documents, devices, computers, phones would contain.
Thank you.
Marty
Martin G. Weinberg, Esq.
20 Park Plaza
Boston, MA 02116
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00015567


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
Subject: [EXTERNAL] Ghislaine Maxwell 02879-506
Date: Wed, 20 Oct 2021 19:18:34 +0000
Good afternoon-
A telephonic court conference will be held tomorrow at noon.
Please confirm that arrangements are in place for Ms. Maxwell's participation.
Please contact me with any questions.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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.
EFTA00016958


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=== Page 1 ===
Event: 3:30-4:00 Epstein conference call
Start Date: 2007-09-27 12:00:00 +0000
End Date: 2007-09-27 12:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2007-09-26 20:30:41 +0000
Date Modified: 2010-11-11 02:32:08 +0000
Priority: 5
EFTA00014168


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c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS)"
(USANYS)"
i
(USANYS)"
>, ,
(USANYS)"
(USANYS)"
,
(USANYS)"
Cc:
)"
,
)"
Subject: RE: Revised Maxwell Indictment
Date: Thu, 25 Jun 2020 19:51:09 +0000
Attachments: 2020-06-25_Maxwell_draft_ indictment_v2.docx
All,
Attached please find a slightly revised draft, incorporating edits from
Thanks,
From:
Sent: Thursday, June 25, 2020 9:43 AM
To:
(USANYS)
>; Craig A.
<
is
(USANYS)
^
>;
(USANYS)
is
(USANYS)
Cc:
>;
)
Subject: Revised Maxwell Indictment
All,
Attached please find the most recent draft of the Maxwell indictment, which incorporates the most recent round of edits
we received.
Thanks,
EFTA00015690


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: RE: Epstein Account Documents
Date: Thu, 07 Oct 2021 16:57:21 +0000
All set, thanks!
From:
(USANYS) [Contractor]
Sent: Thursday, October 7, 2021 12:53 PM
To:
(NY) (FBI)
>;
Cc:
(USANYS)
Subject: RE: Epstein Account Documents
do you want me to save these on the shared somewhere specific? Thanks!
From:
Sent: Thursday, October 7, 2021 7:38 AM
To:
Cc:
(USANYS)
i
(USANYS) [Contractor]
Subject: RE: Epstein Account Documents
I have uploaded the account statement to DOJ USA File Exchange site. I have give you,
and
access rights to the
folder.
If you have any questions, please contact me.
Best
From:
Sent: Wednesday, October 6, 2021 4:12 PM
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Account Documents
Hi
Thanks very much. Could you please send us the account statements for a few months after these documents were
executed? It would be helpful to see the balances.
Thanks!
From:
Sent: Monday, October 4, 2021 8:27 AM
To:
Subject: Epstein Account Documents
EFTA00015137

=== Page 2 ===
As a follow up to our conversation regarding Epstein accounts where Ghislaine Maxwell was a signer on the account, I
have compiled the attached documents for your review.
If you have any question, please contact me.
Best
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00015138


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
Date: Fri, 18 Dec 2020 16:03:32 +0000
Thanks, l'll add it to my list to follow up on in the New Year.
From:
Sent: Thursday, December 17, 2020 11:43 PM
To:
Cc:
Subject: Re: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
I'm struggling to remember what happened after we asked for this. I think
was running point on that.
Sent from my iPhone
On Dec 17, 2020, at 9:57 PM,
wrote:
do you remember what the status is of the estate complying with our subpoena for these kinds of
materials?
Begin forwarded message:
From:
Date: December 17, 2020 at 9:21:12 PM EST
To:
Subject: Jeffrey Epstein Estate Must Share Private Videos Recorded At His Properties
FWIW
https://okmagazine.com/exclusives/jeffrey-epstein-video-recordings-darren-indyke/
Sent from my iPhone
EFTA00016022


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Cc:
)"
,
)"
Subject: Fact Witness Travel Request
Date: Thu, 30 Jan 2020 17:37:24 +0000
Attachments:
Hi
Attached please find a fact witness travel request for a witness who is needed for grand jury prep on February 7th in the
Epstein case. The witness will need to fly up from Florida the day before (February 6th). His cellphone number is included
in the request form, and he should be expecting a call from you or someone in your department to work out the logistics.
Let me know if you need any other information, and thank you so much for your help.
EFTA00016831


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=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc: Christian Everdell
Laura Menninger
, Jeff Pagliuca
Subject: RE: [EXTERNAL]
Boies Articles
Date: Fri, 26 Nov 2021 19:32:03 +0000
Counsel,
This afternoon, we spoke with David Boies and Sigrid McCawley, counsel for
about the articles
you sent. David and Sigrid informed us that the reporting you flagged regarding
is incorrect.
has
no intention of providing any press briefings during the upcoming trial, and her attorneys similarly have no intention of
providing any such briefings or any other commentary to the press during trial. David and Sigrid both confirmed that they
have complied and intend to continue complying with SDNY Local Rule 23.1.
Thank you for raising the issue, and please let us know if there is anything else you would like to discuss in advance of
Monday.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: BOBBI c STERNHEIM
Sent: Wednesday, November 24, 2021 5:56 PM
To:
Cc:
Subject: [EXTERNAL]
/Boies Articles
Attached are the articles we referenced during today's call:
EFTA00016492

=== Page 2 ===
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00016493


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein NPA Appendix
Date: Thu, 27 Jun 2019 14:53:41 +0000
Importance: Normal
OPR will be able to help with this. Copying
who is lead counsel on our investigation.
will respond
separately.
Best,
Director and Chief Counsel
Office of Professional Responsibility
U.S. Department of Justice
Washington, D.C. 20530
www.justice.gov/opr
From:
Sent: Thursday, June 27, 2019 10:37 AM
To:
Cc:
Subject: RE: Epstein NPA Appendix
I do not have it, but OPR should. I have copied
Thanks
From:
Sent: Thursday, June 27, 2019 10:34 AM
To:
Cc:
Subject: Epstein NPA Appendix
Hi
There is non-public appendix to the Epstein NPA that includes a list of victims entitled to receive compensation. Does
ODAG have a copy of it or would you be able to help us retrieve it?
Thank you,
Chief, Public Corruption Unit
EFTA00014460

=== Page 2 ===
United States Attorney's Office for the
Southern District of New York
EFTA00014461


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=== Page 1 ===
Event: Accepted: Epstein Meeting
Start Date: 2020-01-06 17:30:00 +0000
End Date: 2020-01-06 18:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-06 20:47:20 +0000
Date Modified: 2020-01-06 20:47:20 +0000
Priority: 5
DTSTAMP: 2020-01-06 16:21:22 +0000
Attendee:
EFTA00016754


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Fwd: Attempted MAXWELL Visit
Date: Fri, 23 Apr 2021 18:44:14 +0000
FYI-in case you did not hear.
Begin forwarded message:
From:
(USMS)"
Date: April 23, 2021 at 14:30:21 EDT
To:
(USANYS)"
Subject: Attempted MAXWELL Visit
On April 22, 2021, the USMS received a notification from the MDC informing us that an individual Identified as Enver
Ruci attempted to visit Ghislaine Maxwell. According to the officer, Ruci stated that he wanted a legal visit with
MAXWELL and filled out a visitor form that is normally reserved for official legal visitors. The officer did not allow Ruci to
visit and informed him that she had no information on the individual that he was looking to visit with. The following
information was obtained from Enver's New York State driver's license:
Ruci Enver, Address:
,
Staten Island, New York,
Deputy U.S. Marshal
SDNY
EFTA00015641


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re: Briefing in Florida regarding whether the Florida NPA extends to New York
Date: Fri, 26 Jul 2019 02:23:51 +0000
Perfect - call my cell - -
- sent from my iPhone - please excuse brevity and errors.
On Jul 25, 2019, at 8:21 PM,
)
wrote:
Thanks very much. Would 10:00 a.m. tomorrow your time (noon our time) work? If so, we can call you then at
or if not, we could also do 2:00 p.m. your time.
thanks,
From:
Sent: Thursday, July 25, 2019 22:13
To:
Cc:
is
Subject: Re: Briefing in Florida regarding whether the Florida NPA extends to New York
Happy to chat tomorrow. Name your time that's convenient for you.
- sent from my iPhone - please excuse brevity and errors.
On Jul 25, 2019, at 8:07 PM,
wrote:
Thank you for sending us these materials, we appreciate being able to stay up to date, and we'll continue to keep an
eye on the docket for submissions that may be relevant for our investigation.
Separately, might you be available for a quick call sometime tomorrow (Friday) or next week? No rush or emergency,
but we wanted to talk with you about a question in connection with your expertise on the CVRA generally. At your
convenience.
thanks,
From:
Sent: Thursday, July 25, 2019 13:01
To:
)
Cc:
is
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
EFTA00014538

=== Page 2 ===
Hi
I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See
attached. You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies
in the case that relate solely to Florida crimes and Florida victims
because
the
NPA
only
covers
Florida.
We filed our reply brief on remedies on Tuesday - and that should have brought all briefing on remedies for the CVRA
violation to a close. But yesterday Epstein's lawyer (Marty Weinberg) filed a motion for a sur-reply. See attached. In
point (a) on page 2, he argues that he should have an opportunity to file a sur-reply discussing, among other things,
the scope of the NPA. On Monday, we will be filing an opposition to Weinberg extending the briefing further. It
appears that Judge Marra is poised to rule rapidly on the motion for a sur-reply, as he asked for us to respond quickly.
I wanted to make you aware of these developments. My clients were told back in 2013 that the NPA did not extend to
New York or other jurisdictions - and that is the point we are making to Judge Marra.
for Jane Doe 1 and 2
(phone)
(fax)
You can access my publications on
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message.
is admitted to
the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
EFTA00014539


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=== Page 1 ===
From:
To:
Subject: Re: Epstein Investigation
Date: Mon, 30 Jun 2008 23:18:47 +0000
Importance: Normal
Looks like JE went straight to the stockade based on the booking blotter.
Original Message
From:
To: tleopold
Sent: Mon Jun 30 16:59:52 2008
Subject: Epstein Investigation
Dear Ted: Here is my e-mail address and contact information.
Thank you for your assistance.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014159


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: Justice Department opens probe into Jeffrey Epstein plea deal
Date: Wed, 06 Feb 2019 22:09:17 +0000
Importance: Normal
Justice Department opens probe into Jeffrey Epstein plea deal
Miami Herald
By Julie K. Brown
2/6/19
The Department of Justice has opened an investigation into Secretary of Labor Alex Acosta's role in negotiating
a controversial plea deal with a wealthy New York investor accused of molesting more than 100 underage girls in
Palm Beach.
The probe is in response to a request by Sen. Ben Sasse, a a Nebraska Republican and member of the Senate
Judiciary Committee, who raised questions about the case following a series of stories in the Miami Herald. The
Herald articles detailed how Acosta, then the U.S. attorney for the Southern District of Florida, and other DOJ
attorneys worked hand-in-hand with defense attorneys to cut a lenient plea deal with multimillionaire Jeffrey
Epstein in 2008.
The Herald's three-part series, Perversion of Justice,' was cited by Assistant Attorney General Stephen E. Boyd
in his letter to Sasse. DOJ's Office of Professional Responsibility will head the investigation, he said.
"OPR has now opened an investigation into allegations that Department attorneys may have committed
professional misconduct in the manner in which the Epstein criminal matter was resolved," wrote Boyd in the
letter dated Wednesday.
EFTA00015719


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=== Page 1 ===
From:
To:
Subject: Automatic reply: Proposed Epstein Victims' Compensation Program
Date: Fri, 13 Dec 2019 19:34:16 +0000
I am currently traveling for work. Although I have some access to emails, my responses may be delayed. For urgent matters, please contact the
other AUSA(s) on the case.
EFTA00016398


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrants and Orders For
Prospective and Historical Location
APPLICATION
Information and Pen Register
Information for the Cellphones
Mag.
Assigned Call Numbers
and
USAO Reference
No. 2018R01618
Application for Warrants and Orders
for Cellphone Location and Pen Register Information
The United States of America, by its attorney, Audrey Strauss, Acting United States
Attorney for the Southern District of New York,
Assistant United States
,
Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed
Warrants and Orders for prospective and historical location information and pen register
information for two cellphones. As grounds for this Application the Government relies on the
following facts and authorities.
I. Introduction
1. I am an Assistant United States Attorney in the U.S. Attorney's Office for the Southern
District of New York. This Application is submitted in conjunction with the accompanying
affidavit of a law enforcement agent ("Agent Affidavit"), to be sworn before this Court, and
incorporated by reference herein. I make this Application based on information and belief,
including the Agent Affidavit, my review of other documents in the case, and information received
from investigative personnel.
2. The Investigating Agency, Target Cellphones, Subscribers, Target Subject, Service
Providers, Subject Offenses, Successor Service Provider, and Successor Cellphone referenced in
this Application are as specified in the Agent Affidavit.
2019.07.24
EFTA00016349

=== Page 2 ===
II. Legal Authority
A. Prospective Location Information
3. The Government seeks to obtain both precision location information and cell site data
for the Target Cellphones on a prospective basis (the "Prospective Location Information") for a
period of 45 days from the date of this order - the same period of time for which a warrant for a
tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the
Prospective Location Information may permit "tracking" the user of the phone in the colloquial
sense, this is not an application for a warrant for a "tracking device" as defined in Fed. R. Crim.
P. 41(a)(2)(E) and 18 U.S.C. $ 3117(b). Those provisions only apply where an agent is seeking to
physically install a tracking device on a given object. Instead, the Prospective Location
Information will be obtained by requiring the Service Provider to provide the information.
4. The authority for this application is found in 18 U.S.C. § 2703(c)(1), which authorizes
a court of competent jurisdiction to require any electronic communication service provider (which
includes a cellular telephone service provider¹) to disclose any "record or other information
pertaining to a subscriber" other than the "contents of communications," when the government
obtains, inter alia, a warrant under the applicable procedures of Rule 41. See 18 U.S.C. $
2703(c)(1)(A). Because data concerning a subscriber's location, such as precision location
information and cell site data, constitutes "information pertaining to a subscriber" that does not
include the "contents of communications," that data is among the types of information available
1 See 18 U.S.C. $ 2711(1) (incorporating by cross-reference statutory definitions set forth in 18
U.S.C. $ 2510); 18 U.S.C. $ 2510(15) (defining "electronic communication service" as "any
service which provides to users thereof the ability to send or receive wire or electronic
communications").
2
2019.07.24
EFTA00016350

=== Page 3 ===
under $ 2703(c)(1)(A).² Further, as specified in 18 U.S.C. $ 2711(3), this Court is a court of
competent jurisdiction under the Stored Communications Act because it has jurisdiction over the
Subject Offenses.
5. The Government's request for cell site data also implicates the pen register statute,
because such data constitutes signaling information used by the Service Providers to route
communications to and from the Target Cellphones. In order to collect such data, a valid pen
register order is required.³ Accordingly, I hereby certify pursuant to 18 U.S.C. § 3122 that such
signaling information is relevant to an ongoing investigation being conducted by the Investigating
Agency into suspected violations of the Subject Offenses by the Target Subject.
B. Historical Location Information
6. The Government also seeks historical cell site data for the Target Cellphones for the
period from June 1, 2020 to the present (the "Historical Location Information"). Because such
data-like "Prospective Location Information"-constitutes information concerning a subscriber,
the Court is authorized to order the Service Providers to provide this data pursuant to a warrant
2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.)
(cellphone location information falls within $ 2703(c)(1)); accord, e.g., United States V. Caraballo,
963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008);
In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849
F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting view that cellular location data falls within the scope
of the SCA and finding that phone must be treated as "tracking device" for purposes of Rule 41
where used to collect location data); In re Application, 2009 WL 159187, at *5-*6 (S.D.N.Y.
Jan. 13, 2009) (McMahon, J.) (same).
3 See 18 U.S.C. $ 3121 (prohibiting use of pen register or trap and trace device without an order
under the pen register statute); 3127(3) & (4) (defining pen register and trap and trace device to
include devices or processes that record, inter alia, signaling information). Although cell site data
constitutes "signaling" information within the meaning of the pen register statute, a separate statute
precludes the Government from relying "solely" on the authority provided by the pen register
statute to ascertain a subscriber's location. 47 U.S.C. § 1002(a). Here, the Government seeks to
obtain such data pursuant to 18 U.S.C. $ 2703(c) as well as the pen register statute, rather than
"solely" under the latter statute. See In re Application, 460 F. Supp. 2d at 456-59.
3
2019.07.24
EFTA00016351

=== Page 4 ===
application under 18 U.S.C. $ 2703(c), under the applicable procedures of Rule 41. See 18 U.S.C.
$ 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's
request for a warrant to obtain the Prospective Location Information requested above also supports
the issuance of a warrant under $ 2703(c) for the requested Historical Location Information. In
addition, the Government seeks toll records for the same period as the Historical Location
Information. Pursuant to 18 U.S.C. § 2703(d), I respectfully submit that the Agent Affidavit offers
specific and articulable facts showing that there are reasonable grounds to believe that the toll
record information sought is relevant and material to an ongoing criminal investigation.
C. Pen Register Information
7. Finally, the Government seeks an order pursuant to 18 U.S.C. §§ 3121-26 authorizing
the use of a pen register on the Target Cellphones for a period of 45 days from the date of this
order. Specifically, the Government seeks an order directing the Service Providers to furnish any
information, facilities, and technical assistance necessary to operate, unobtrusively and with
minimum disruption of service, a pen register and trap and trace device to capture all dialing,
routing, addressing, or signaling information associated with each call transmitted to or from the
Target Cellphones, as specified further in the proposed Warrants and Orders (the "Pen Register
Information").
4 The Government is also not seeking authorization to obtain post-cut-through dialed digits
("PCTDD"), or digits that are dialed after a telephone call from the Target Cellphones has been
connected. Pursuant to the attached Order, if possible, the Service Provider will forward only pre-
cut-through-dialed digits to the Investigating Agency. However, if the Service Providers'
technical capabilities require it to forward all dialed digits, including PCTDD, to the Investigating
Agency, the Investigating Agency will only decode and forward to the agents assigned to the
investigation the numbers that are dialed before the call is cut through.
4
2019.07.24
EFTA00016352

=== Page 5 ===
8. I hereby certify pursuant to 18 U.S.C. $ 3122 that the Pen Register Information is
relevant to an ongoing investigation being conducted by the Investigating Agency into suspected
violations of the Subject Offenses by the Target Subject.
D. Sealing and Non-Disclosure Order to Service Providers
9. When the Government obtains records or information under $ 2703(c), it is not required
to notify the subscriber or customer. 18 U.S.C. § 2703(c)(3). Additionally, the Government may
obtain an order precluding the Service Providers from notifying the subscriber or any other third-
party of the warrant or order obtained, for such period as the Court deems appropriate, where there
is reason to believe that such notification will result in endangering the life or physical safety of
an individual, flight from prosecution, destruction of or tampering with evidence, or intimidation
of potential witnesses, or will otherwise seriously jeopardize the investigation. 18 U.S.C.
$ 2705(b).
10. Further, 18 U.S.C. $ 3123(d) provides that an order directing installation of a pen
register or trap and trace device shall direct the pertinent service provider "not to disclose the
existence of the pen register or trap and trace device or the existence of the investigation to the
listed subscriber, or to any other person unless or until otherwise ordered by the Court."
11. Accordingly, as explained further in the Agent Affidavit, in light of the confidential
nature of the continuing criminal investigation and the adverse consequences expected in the event
of premature notification, the Government respectfully requests that the Court direct the Service
Providers not to notify the Subscribers or any other person of the Warrants and Orders sought
herein for a period of one year, subject to extension upon application to the Court, if necessary.
12. For similar reasons, I respectfully request that the proposed Warrants and Orders, this
Application, and the accompanying Agent Affidavit, be maintained under seal until the Court
orders otherwise, except that the Government be permitted without further order of this Court to
5
2019.07.24
EFTA00016353

=== Page 6 ===
serve these Warrants and Orders on the Service Providers; provide copies of the Warrants and
Orders or the supporting Application and Agent Affidavit as need be to personnel assisting the
Government in the investigation and prosecution of this matter; and disclose these materials as
necessary to comply with discovery and disclosure obligations in any prosecutions related to this
matter.
III. Prior Requests
13. Except as may be set forth above, no prior request for the relief requested herein has
been made.
Dated: New York, New York
June 29, 2020
Assistant United States Attorney
Tel.:
6
2019.07.24
EFTA00016354

=== Page 7 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrants and Orders For
Prospective and Historical Location
AGENT AFFIDAVIT
Information and Pen Register
Information for the Cellphones
Assigned Call Numbers
Mag.
and
USAO Reference
No. 2018R01618
Agent Affidavit in Support of Warrants and Orders
for Cellphone Location and Pen Register Information
STATE OF NEW YORK
)
) SS.
COUNTY OF NEW YORK )
,
being duly sworn, deposes and states:
I. Introduction
1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI" or
"Investigating Agency") since 2017. As such, I am a "federal law enforcement officer" within the
meaning of Federal Rule of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged
in enforcing the criminal laws and duly authorized by the Attorney General to request a search
warrant. I am currently assigned to investigate violations of criminal law relating to the sexual
exploitation of children as part of an FBI Task Force. I have gained expertise in this area through
classroom training and daily work related to these types of investigations. As part of my
responsibilities, I have been involved in the investigation of cases involving sex trafficking,
enticement of minors, and transportation of minors for illegal sex acts, and have participated in the
execution of search warrants involving electronic evidence.
2. Requested Information. I respectfully submit this Affidavit pursuant to 18 U.S.C.
§§ 2703(c) and (c)(1)(A) and the applicable procedures of Federal Rule of Criminal Procedure 41;
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18 U.S.C. §§ 2703(d) & 2705; and 18 U.S.C. §§ 3121-3126, in support of two warrants and orders
for prospective location information, historical location information, toll records, and pen register
information, for the Target Cellphones identified below (collectively, the "Requested
Information").
3. Basis for Knowledge. This Affidavit is based upon my participation in the
investigation, my examination of reports and records, and my conversations with other law
enforcement agents and other individuals, as well as my training and experience. Because this
Affidavit is being submitted for the limited purpose of obtaining the Requested Information, it
does not include all the facts that I have learned during the course of this investigation. Where the
contents of documents and the actions, statements, and conversations of others are reported herein,
they are reported in substance and in part, except where otherwise indicated. In addition, unless
otherwise indicated, statements by others referenced in this Affidavit were not necessarily made
to me, but may have been provided to me by someone else to whom I have spoken or whose report
I have read (and who in turn may have had either direct or indirect knowledge of the statement).
Similarly, unless otherwise indicated, information in this Affidavit resulting from surveillance
does not necessarily set forth my personal observations, but may have been provided to me by
other law enforcement agents who observed the events, and to whom I have spoken or whose
report I have read.
4. Target Cellphones, Subscribers, Target Subject, and Service Providers. The
Target Cellphones referenced in this Affidavit are the cellphone assigned call number
("Target Cellphone-1") and the cellphone assigned call number
("Target
Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further
discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc."
2
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("Subscriber-1"), and Target Cellphone-2 is subscribed to in the name of "G Max" ("Subscriber-
2," and collectively with Subscriber-1, the "Subscribers"). GHISLAINE MAXWELL is believed
to use the Target Cellphones and is a Target Subject of this investigation. T-Mobile is the Service
Provider for Target Cellphone-1, and AT&T is the Service Provider for Target Cellphone-2.
5. Precision Location Capability. Cellphone service providers have technical
capabilities that allow them to collect at least two kinds of information about the locations of the
cellphones to which they provide service: (a) precision location information, also known as E-911
Phase II data, GPS data, or latitude-longitude data, and (b) cell site data, also known as
"tower/face" or "tower/sector" information. Precision location information provides relatively
precise location information about a cellphone, which a provider can typically collect either via
GPS tracking technology built into the phone or by triangulating the device's signal as received
by the provider's nearby cell towers. Cell site data, by contrast, reflects only the cell tower and
sector thereof utilized in routing any communication to and from the cellphone, as well as the
approximate range of the cellphone from the tower during the communication (sometimes referred
to as "per-call measurement" ("PCM") or "round-trip time" ("RTT") data). Because cell towers
are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart in rural
areas, cell site data is typically less precise than precision location information. Based on my
training and experience, I know that the Service Providers have the technical ability to collect
precision location information from any cellphone on its network, including by initiating a signal
on the Service Providers' network to determine the phone's location. I further know that cell site
3
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data is routinely collected by the Service Providers in the course of routing calls placed to or from
any cellphone on their network.
6. Successor Service Provider. Because it is possible that the Target Subject may change
cellphone service provider during the course of this investigation, it is requested that the warrant
and investigative order requested apply without need for further order to any Successor Service
Provider who may provide service to the Target Cellphones during the time frames at issue herein.
II. Facts Establishing Probable Cause
7. Although I understand that probable cause is not necessary to obtain all of the
Requested Information, I respectfully submit that probable cause exists to believe that the
Requested Information will lead to the location of a person, GHISLAINE MAXWELL, to be
arrested for the crimes of conspiracy to entice minors to travel to engage in illegal sex acts, in
violation of 18 U.S.C. $ 371; enticement of a minor to travel to engage in illegal sex acts, in
violation of 18 U.S.C. § 2422; conspiracy to transport minors with intent to engage in criminal
sexual activity, in violation of 18 U.S.C. $ 371; transporting a minor with intent to engage in
criminal sexual activity, in violation of 18 U.S.C. $ 2423(a); and perjury, in violation of 18 U.S.C.
$ 1623 (the "Subject Offenses").
8. On June 29, 2020, a grand jury in the Southern District of New York returned an
indictment charging GHISLAINE MAXWELL with the Subject Offenses. The Indictment
charging MAXWELL is attached as Exhibit A hereto (the "Indictment"). That same day, United
States Magistrate Judge Lisa Margaret Smith signed a warrant for MAXWELL's arrest, which is
attached as Exhibit B hereto (the "Arrest Warrant").
1 Toll records are sometimes necessary or helpful in order to obtain or interpret historical cell site
data and are therefore also requested herein.
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9. In light of these pending charges in the Indictment and the issuance of the Arrest
Warrant, GHISLAINE MAXWELL is subject to arrest for the Subject Offenses.
10. Based on my review of T-Mobile records, I have learned that Target Cellphone-1 is
subscribed in the name of "Terramar Project, Inc." Based on my review of publicly available
videos and related information, I know that GHISLAINE MAXWELL has given multiple public
addresses in her capacity as the founder and president of an organization known as the TerraMar
Project, a non-profit organization that, as noted, was founded and run by MAXWELL and devoted
to ocean protection.
11. As set forth in Paragraph 3 of Exhibit A, MAXWELL was a close associate and
employee of Jeffrey Epstein's. Additionally, as set forth in Paragraphs 1 through 19 of Exhibit A,
MAXWELL is charged with committing four of the Subject Offenses together with Epstein. I
know from my participation in this investigation that on or about July 6, 2019, Epstein was arrested
by the FBI on federal sex trafficking charges. During that arrest, the FBI seized an iPhone from
Epstein's possession (the "Epstein Phone"). Pursuant to a judicially authorized search warrant,
the FBI subsequently searched the contents of the Epstein Phone. Among other things, that search
revealed that the phone number associated with Target Cellphone-1 was saved as a contact in the
Epstein Phone under the name "Ghislaine."
12. I further know from my review of T-Mobile records the following:
a. Target Cellphone-1 has been active within the last 30 days.
b. Target Cellphone-1 has been in contact with a phone subscribed to in the name
of "Joshua Perry," which I know from my review of a law enforcement database is the name of
the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Phone"). The most recent
contact between Target Cellphone-1 and the Joshua Perry Phone occurred in or about May 2020.
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c. Target Cellphone-1 has also been in contact with a phone subscribed to the
business "Haddon, Morgan, & Foreman," which I know from my review of court records is the
name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the
"Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and
the Haddon, Morgan, & Foreman Phone occurred in or about February 2020.
d. Target Cellphone-1 has also been in contact with a phone subscribed to in the
name of "Isabel Maxwell," which I know from my review of a law enforcement database is the
name of GHISLAINE MAXWELL's sister (the "Isabel Maxwell Phone"). The most recent
contact between Target Cellphone-1 and the Isabel Maxwell Phone occurred in or about August
2019.
e. Target Cellphone-1 has also been in contact with a phone subscribed to in the
name of "Laura Menninger," which I know from my review of court records is the name of an
attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Menninger Phone"). The most recent contact between Target Cellphone-1 and the Laura
Menninger Phone occurred in or about August 2019.
f. Target Cellphone-1 has also been in contact with a phone subscribed to in the
name of "Scott Borgerson," which I know from my review of bank records and Amazon records
is the name of an individual with whom GHISLAINE MAXWELL shares a joint bank account
and to whom MAXWELL's Amazon account has sent multiple packages within approximately
the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1
and the Scott Borgerson Phone occurred in or about August 2019.
13. Accordingly, I respectfully submit there is probable cause to believe that the location
of Target Cellphone-1 will reveal the location of GHISLAINE MAXWELL.
6
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14. Based on my review of AT&T records, I have learned that Target Cellphone-2 is
subscribed in the name of "G Max," which appears to be a shortened version of GHISLAINE
MAXWELL's name. I further know from my review of AT&T records that Target Cellphone-2
has been active within the last 30 days. In particular, within the last 30 days, Target Cellphone-2
has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon,
Morgan, & Foreman Phone, and the Scott Borgerson Phone.
15. Accordingly, I respectfully submit that there is probable cause to believe that the
location of Target Cellphone-2 will reveal the location of GHISLAINE MAXWELL.
III. Request for Warrants and Orders
16. Based on the foregoing, I respectfully request that the Court require the Service
Providers to provide the Requested Information as specified further in the Warrants and Orders
proposed herewith, including prospective precision location and cell site data for a period of 45
days from the date of this Order, historical cell site data and toll records for the period from June
1, 2020 through the date of this Order, and pen register information for a period of 45 days from
the date of this Order.
1.
Nondisclosure. The scope of this ongoing criminal investigation and existence of
the Indictment and Arrest Warrant are not publicly known. As a result, premature public disclosure
of this affidavit or the requested Warrants and Orders could alert GHISLAINE MAXWELL that
she is under investigation and subject to arrest, causing her to destroy evidence, flee from
prosecution, or otherwise seriously jeopardize the investigation. Specifically:
a. As evidenced by the charges alleged in the Indictment, MAXWELL is known
to have participated in acts of sexual abuse of minors. Alerting her to the existence and scope of
the investigation may lead her to intimidate witnesses. See 18 U.S.C. $ 2705(b)(1),(4).
7
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b. Additionally, the Target Subject is at liberty in the community. Premature
disclosure of the existence of this application and the charges contained in the Indictment could
result in the Target Subject fleeing from prosecution if she were made aware of the pending charges
before arrest. See 18 U.S.C. $ 2705(b)(2).
17. Accordingly, there is reason to believe that, were the Service Providers to notify the
subscribers or others of the existence of the warrant, the investigation would be seriously
jeopardized. Pursuant to 18 U.S.C. $ 2705(b), I therefore respectfully request that the Service
Providers be directed not to notify the subscribers or others of the existence of the Warrants and
Orders for a period of one year, and that the Warrants and Orders and all supporting papers be
maintained under seal until the Court orders otherwise, as specified in the Application submitted
in conjunction with this Affidavit.
Special Agent
Federal Bureau of Investigation
Sworn to before me this
day of June, 2020
HONORABLE KATHARINE H. PARKER
United States Magistrate Judge
Southern District of New York
8
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrant and Order For Prospective
and Historical Location Information and
WARRANT AND ORDER
Pen Register Information for the
Cellphone Assigned Call Number
USAO Reference No.
,
Mag.
2018R01618
Warrant and Order
for Cellphone Location Information and Pen Register Information
and for Sealing and Non-Disclosure
TO:
T-Mobile ("Service Provider"), and any subsequent provider of service to the Target
Cellphone specified below ("Subsequent Service Provider")
Federal Bureau of Investigation ("Investigative Agency")
Upon the Application and Agent Affidavit submitted by the Government in this matter:
I. Findings
The Court hereby finds:
1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is
assigned call number
,
is subscribed to in the name of "Terramar Project, Inc." (the
"Subscriber"), and is currently serviced by the Service Provider.
2. Pursuant to 18 U.S.C. $ 2703(c)(1)(A) and the applicable provisions of Rule 41 of the
Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
believe that the prospective and historical location information for the Target Cellphone will reveal
the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a),
and 1623 ("the Subject Offenses").
3. Pursuant to 18 U.S.C. $ 2703(d), the Government's application also sets forth specific
and articulable facts showing that there are reasonable grounds to believe that the toll records for
the Target Cellphone are relevant and material to an ongoing criminal investigation.
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4. Pursuant to 18 U.S.C. $ 3123(b)(1), the Government has certified that the pen register
information for the Target Cellphone is relevant to an ongoing investigation by the Investigating
Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations
of the Subject Offenses.
5. Pursuant to 18 U.S.C. $ 2705(b), there is reason to believe that notification of the
existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of
potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C.
§§ 2701 et seq., and 18 U.S.C. $ 3103a, IT IS HEREBY ORDERED:
II. Order to Service Provider
6. Service Provider. This Order shall apply to the Service Provider specified above, and
to any subsequent provider of service to the Target Cellphone without need for further Order of
this Court.
7. Prospective Location Information. The Service Provider shall provide to the
Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order,
information concerning the location of the Target Cellphone ("Prospective Location
Information"), including all available:
a. precision location information, including GPS data, E-911 Phase II data, and
latitude-longitude data; and
b. cell site data, including any data reflecting (a) the cell towers and sectors thereof
utilized in routing any phone, text, or data communication to or from the Target Cellphone, and
(b) the approximate range of the target phone from the cell towers during the communication
(including per-call measurement ("PCM") or round-trip time ("RTT") data);
2
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8. Historical Location Information and Toll Records. The Service Provider shall
provide to the Investigating Agency all available historical cell site location information reflecting
the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or
from the Target Cellphone, and the approximate range of the target phone from the cell towers
during the communication (PCM/RTT data), for the period from June 1, 2020 through the present,
as well as all available toll records (including call detail, SMS detail, or data session detail records)
for the communications.
9. Pen register with caller identification and/or trap and trace device. The Service
Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this
order, all dialing, routing, addressing, or signaling information associated with each voice, text, or
data communication transmitted to or from the Target Cellphone, including but not limited to:
a. any unique identifiers associated with the phone, including ESN, MEIN,
MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
b. source and destination telephone numbers and/or Internet protocol ("IP")
addresses;
c. date, time, and duration of the communication; and
d. cell-site information as specified above.
1 The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or
digits that are dialed after a telephone call from the Target Phone has been connected. If possible,
the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency.
However, if the Service Provider's technical capabilities require it to forward all dialed digits,
including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and
forward to the agents assigned to the investigation, the numbers that are dialed before the call is
cut through.
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10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all
information, facilities, and technical assistance necessary to accomplish the disclosure of all of the
foregoing information relating to the Target Cellphone unobtrusively and with the minimum
interference to the service presently provided to the Subscriber.
11. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers,
employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying
investigation, to the Subscriber or any other person, for a period of one year from the date of this
Warrant and Order, subject to extension upon application to the Court, if necessary.
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=== Page 19 ===
III. Additional Provisions
12. Compensation for Costs. The Investigating Agency shall compensate the Service
Provider for reasonable expenses incurred in complying with the Warrant and this Order.
13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit,
shall be sealed until otherwise ordered by the Court, except that the Government may without
further order of this Court: serve this Warrant and Order on the Service Provider; provide copies
of the Warrant and Order or the supporting Application and Agent Affidavit as need be to
personnel assisting the Government in the investigation and prosecution of this matter; and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
Dated: New York, New York
Date Issued
Time Issued
UNITED STATES MAGISTRATE JUDGE
Southern District of New York
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=== Page 20 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrant and Order For Prospective
and Historical Location Information and
WARRANT AND ORDER
Pen Register Information for the
Cellphone Assigned Call Number
USAO Reference No.
,
Mag.
2018R01618
Warrant and Order
for Cellphone Location Information and Pen Register Information
and for Sealing and Non-Disclosure
TO: AT&T ("Service Provider"), and any subsequent provider of service to the Target
Cellphone specified below ("Subsequent Service Provider")
Federal Bureau of Investigation ("Investigative Agency")
Upon the Application and Agent Affidavit submitted by the Government in this matter:
I. Findings
The Court hereby finds:
1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is
assigned call number
,
is subscribed to in the name of "G Max" (the "Subscriber"),
and is currently serviced by the Service Provider.
2. Pursuant to 18 U.S.C. $ 2703(c)(1)(A) and the applicable provisions of Rule 41 of the
Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
believe that the prospective and historical location information for the Target Cellphone will reveal
the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a),
and 1623 ("the Subject Offenses").
3. Pursuant to 18 U.S.C. § 2703(d), the Government's application also sets forth specific
and articulable facts showing that there are reasonable grounds to believe that the toll records for
the Target Cellphone are relevant and material to an ongoing criminal investigation.
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4. Pursuant to 18 U.S.C. $ 3123(b)(1), the Government has certified that the pen register
information for the Target Cellphone is relevant to an ongoing investigation by the Investigating
Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations
of the Subject Offenses.
5. Pursuant to 18 U.S.C. $ 2705(b), there is reason to believe that notification of the
existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of
potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C.
§§ 2701 et seq., and 18 U.S.C. § 3103a, IT IS HEREBY ORDERED:
II. Order to Service Provider
6. Service Provider. This Order shall apply to the Service Provider specified above, and
to any subsequent provider of service to the Target Cellphone without need for further Order of
this Court.
7. Prospective Location Information. The Service Provider shall provide to the
Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order,
information concerning the location of the Target Cellphone ("Prospective Location
Information"), including all available:
a. precision location information, including GPS data, E-911 Phase II data, and
latitude-longitude data; and
b. cell site data, including any data reflecting (a) the cell towers and sectors thereof
utilized in routing any phone, text, or data communication to or from the Target Cellphone, and
(b) the approximate range of the target phone from the cell towers during the communication
(including per-call measurement ("PCM") or round-trip time ("RTT") data);
2
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=== Page 22 ===
8. Historical Location Information and Toll Records. The Service Provider shall
provide to the Investigating Agency all available historical cell site location information reflecting
the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or
from the Target Cellphone, and the approximate range of the target phone from the cell towers
during the communication (PCM/RTT data), for the period from June 1, 2020 through the present,
as well as all available toll records (including call detail, SMS detail, or data session detail records)
for the communications.
9. Pen register with caller identification and/or trap and trace device. The Service
Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this
order, all dialing, routing, addressing, or signaling information associated with each voice, text, or
data communication transmitted to or from the Target Cellphone, including but not limited to:
a. any unique identifiers associated with the phone, including ESN, MEIN,
MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
b. source and destination telephone numbers and/or Internet protocol ("IP")
addresses;
c. date, time, and duration of the communication; and
d. cell-site information as specified above.
1 The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or
digits that are dialed after a telephone call from the Target Phone has been connected. If possible,
the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency.
However, if the Service Provider's technical capabilities require it to forward all dialed digits,
including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and
forward to the agents assigned to the investigation, the numbers that are dialed before the call is
cut through.
3
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=== Page 23 ===
10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all
information, facilities, and technical assistance necessary to accomplish the disclosure of all of the
foregoing information relating to the Target Cellphone unobtrusively and with the minimum
interference to the service presently provided to the Subscriber.
11. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers,
employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying
investigation, to the Subscriber or any other person, for a period of one year from the date of this
Warrant and Order, subject to extension upon application to the Court, if necessary.
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=== Page 24 ===
III. Additional Provisions
12. Compensation for Costs. The Investigating Agency shall compensate the Service
Provider for reasonable expenses incurred in complying with the Warrant and this Order.
13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit,
shall be sealed until otherwise ordered by the Court, except that the Government may without
further order of this Court: serve this Warrant and Order on the Service Provider; provide copies
of the Warrant and Order or the supporting Application and Agent Affidavit as need be to
personnel assisting the Government in the investigation and prosecution of this matter; and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
Dated: New York, New York
Date Issued
Time Issued
UNITED STATES MAGISTRATE JUDGE
Southern District of New York
5
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: subpoena of
Date: Thu, 01 Aug 2019 02:59:56 +0000
Following up on our conversation earlier this week, I wanted to write to confirm that we are requesting records in the
custody and control of
relating to flights on Mr. Epstein jet(s), including but not limited to
log book(s). I
expect that we will formally issue a subpoena but wanted to let you know in the first instance. We also discussed
following up on the topics of how
came to work for Mr. Epstein, both in 2005 and 2015. Please let me
know if any additional information would be helpful, and we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00014544


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=== Page 1 ===
From:
)"
To: "McGorty, Glen"
,
)"
Cc: "Zelenko, Daniel"
, "Giffuni, Danielle"
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Wed, 18 Nov 2020 15:51:51 +0000
Attachments:
(fully_executed).pdf
Glen,
Attached please find the fully executed proffer agreement with the agent's initials and my initials added.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, November 17, 2020 9:30 PM
To: McGorty, Glen
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
Received, thank you very much, Glen.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00015013

=== Page 2 ===
From: McGorty, Glen
Sent: Tuesday, November 17, 2020 8:21 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
--- sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
I
Web
Bio
Privileged and Confidential
Attorney-Client Communication
Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Wednesday, November 11, 2020 1:43 PM
To: McGorty, Glen
is
)
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I expect one
of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those traveling with
Epstein to enter the country, including any steps that allowed Epstein or those traveling with him to avoid
processing that travelers would normally undergo.
Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00015014

=== Page 3 ===
From: McGorty, Glen
Sent: Tuesday, November 10, 2020 1:16 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully prepared, so
if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
I
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 26, 2020 6:19 PM
To: McGorty, Glen
is
)
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border Protection
employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I expect we will ask for
an approximate timeline of when Mr.
met and interacted with
the nature of those interactions, and any
interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
EFTA00015015

=== Page 4 ===
From: McGorty, Glen
Sent: Monday, October 26, 2020 11:58 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
-
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on Thursday, 11/12.
Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Thursday, October 22, 2020 10:33 AM
To:
>; ; McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via
WebEx. Are there any days the week of November 9th when your team and Mr.
would be available? We would
expect this proffer to be much shorter than our first, and certainly no more than two hours at most.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00015016

=== Page 5 ===
From:
Sent: Friday, October 9, 2020 4:42 PM
To: McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From: McGorty, Glen
Sent: Thursday, October 8, 2020 9:31 AM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
I
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 5, 2020 4:14 PM
To: McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
is
Subject: RE: Wednesday's WebEx
External Email
EFTA00015017

=== Page 6 ===
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues crop up,
and we'd be happy to work through them.
Thanks,
From: McGorty, Glen
Sent: Monday, October 5, 2020 12:48 PM
To:
is
>;
(USANYS)
Cc: Zelenko, Daniel
is
>; Giffuni, Danielle
>;
Morrissey, Josh
Subject: Wednesday's WebEx
,
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan, Danielle
and Mr.
but also Josh Morrissey who is in our IT group and will make sure we are good to go for our meeting.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com I Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
EFTA00015018


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=== Page 1 ===
From:
"
To:
Cc:
Subject: US V. Maxwell - Hard Drive
Date: Sat, 20 Nov 2021 21:49:38 +0000
Attachments: 2021.11.20_MDC - Maxwell_PASSWORD.pdf
H
e,
We wanted to let you know that we sent a hard drive for Ms. Maxwell via FedEx today. I am attaching the letter we sent
with the password. Here are the FedEx tracking numbers:
FedEx tracking number for drive sent to MDC:
FedEx tracking number for password sent to MDC:
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
3
EFTA00014653


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=== Page 1 ===
From:
To:
Subject: 20-2413 Giuffre V. Maxwell "Notice of Telephonic Date Acknowledgment FILED"
Date: Fri, 09 Oct 2020 16:35:39 +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 10/09/2020
Case Name:
Giuffre V. Maxwell
Case Number: 20-2413
Document(s): Document(s)
Docket Text:
NOTICE OF HEARING DATE ACKNOWLEDGMENT, on behalf of Appellant Ghislaine Maxwell, FILED.
Service date 10/09/2020 by CM/ECF. Note: Listed counsel must log on to CM/ECF in order to view the
attachment. [2949178] [20-2413]
Notice will be electronically mailed to:
Mr. David Boies, -:
Mr. Jay Marshall Wolman, -:
Mr. Bruce D. Brown, -:
Ms. KatieLynn B. Townsend, -:
Sigrid S. McCawley, Partner:
Ty Gee, -:
Adam Mueller, -:
Marc Randazza, -:
Christine Walz, -:
Mr. Sanford Bohrer, -:
Laura Menninger, -:
Imran H. Ansari, -:
Jason Wang, Deputy Clerk:
Calendar E-Box, -: -
Notice will be stored in the notice cart for:
EFTA00014595

=== Page 2 ===
Jason Wang, Deputy Clerk
Calendar E-Box, -
The following document(s) are associated with this transaction:
Document Description: Notice of Telephonic Date Acknowledgment FILED
Original Filename: 2020.10.09 Maxwell Notice of Hearing Date Acknowledgment Form.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=10/09/2020] [FileNumber=2949178-0]
[5c33594f14de34be21447fec318e8a218492204624bb092f270c6385c67edc6bf6543c1c73252140c6bbf30c8ca73
de3652d931362e031ce41a63015c20a8ac9]]
EFTA00014596


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: hmm
Date: Mon, 24 Feb 2020 21:34:53 +0000
Attachments: 31000152314782_transcript.pdf
Found it! Last page of the attached.
From:
Sent: Monday, February 24, 2020 12:45
To:
Cc:
Subject: RE: hmm
do you remember where you saw this? Trying to run this down. Thanks.
EFTA00016915


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
Defendant.
:
:
:
X
MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT,
MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE
OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO
AND
TO DISMISS COUNTS FIVE AND SIX
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Denver, CO 80203
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
York, NY 10022
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Attorneys for Ghislaine Maxwell
EFTA00015303

=== Page 2 ===
TABLE OF CONTENTS
TABLE OF CONTENTS
i
TABLE OF AUTHORITIES
ii
FACTUAL BACKGROUND
1
ARGUMENT
2
I.
The government's violation of the Fourth Amendment requires suppression
2
A. The subpoena violated the Fourth Amendment because it was unconstitutionally
overbroad.
4
B.
The government's subpoena to
was an unconstitutional warrantless Fourth
Amendment search
6
1.
The third-party doctrine does not compel a different result.
8
C.
The government's subpoena to
was an unconstitutional Fourth
Amendment seizure.
11
II.
The government's violation of Martindell requires suppression
11
III. The government's violation of the Fifth Amendment requires suppression
15
Conclusion
17
Certificate of Service
18
i
EFTA00015304

=== Page 3 ===
TABLE OF AUTHORITIES
Cases
Boyd V United States, 116 U.S. 616 (1886)
3, 6, 15
Carpenter V. United States, 138 S. Ct. 2206 (2018)
3, 5, 6, 9
Colorado V. Bannister, 449 U.S. 1 (1980)
3
DeMassa V. Nunez, 770 F.2d 1505 (9th Cir. 1985)
10
Doe V. Broderick, 225 F.3d 440 (4th Cir. 2000)
10, 13
Fisher V. United States, 425 U.S. 391 (1976)
3, 15
Hale V. Henkel, 201 U.S. 43 (1906)
2,4
In re Grand Jury Subpoena Duces Tecum, 945 F.2d 1221 (2d Cir. 1991)
14
In re Grand Jury Subpoena, JK-15-029, 828 F.3d 1083 (9th Cir. 2016)
4, 5, 11
Katz V. United States, 389 U.S. 347 (1967)
2,6
Murphy V. Waterfront Comm'n of New York Harbor, 378 U.S. 52 (1964)
2
Palmieri V. State of New York, 779 F.2d 861 (2d Cir. 1985)
14
People V. Gutierrez, 222 P.3d 925 (Colo. 2009)
10
People V. Mason, 989 P.2d 757 (Colo. 1999)
8
Smith V. Maryland, 442 U.S. 735, 740 (1979)
passim
United States V. Calandra, 414 U.S. 338 (1974)
6
United States V. Di Re, 332 U.S. 581 (1948)
6
United States V. Dionisio, 410 U.S. 1 (1973)
2, 15
United States V. Miller, 425 U.S. 435 (1976)
9, 10
United States V. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)
16
United States V. Place, 462 U.S. 696 (1983)
3
United States V. Thomas, 736 F.3d 54 (1st Cir. 2013)
6
ii
EFTA00015305

=== Page 4 ===
Constitutional Provisions
U.S. CONST. amend. IV
passim
U.S. CONST. amend. V
passim
iii
EFTA00015306

=== Page 5 ===
Ghislaine Maxwell moves under the Fourth Amendment, Martindell V. Int'l Tel. & Tel.
Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the
government obtained from a grand jury subpoena it issued to
and to
dismiss Counts Five and Six, which are the fruits of that unlawful subpoena.
FACTUAL BACKGROUND
Ms. Maxwell's Motion under the Due Process Clause to Suppress and Dismiss Counts 5
and 6 sets forth the facts relevant to this motion. Ms. Maxwell incorporates those facts by
reference here.
In summary, the government obtained
file, including the
by way of a grand jury subpoena enforced through an ex parte
proceeding
Although the government claimed not to know what was in
file and that
had no role in instigating the investigation of
Maxwell, both of these representations to
were false.
In turn, the government issued
in the
See Motion under the Due Process Clause to Suppress and
Dismiss Counts 5 and 6, Ex. C, at 3. The government could have been, but was not, more
targeted in its approach. The government has not provided Maxwell with a copy of the subpoena,
but the record shows that the subpoena was incredibly broad and, as explained below, ultimately
unlawful.
The subpoena violated the Fourth Amendment because it was overbroad and because it
effected a warrantless search and seizure of material in which Maxwell had a reasonable
expectation of privacy. Moreover, by securing a modification of the Protective Order through a
secret, ex parte proceeding, the government violated Martindell V. Int 'l Tel. & Tel. Corp., 594
1
EFTA00015307

=== Page 6 ===
F.2d 291 (2d Cir. 1979), which required the government to give Maxwell notice and an
opportunity to be heard on its request. And in bypassing Martindell and eviscerating the
guarantee of confidentiality provided by the Protective Order, the government trampled on
Maxwell's Fifth Amendment privilege against self-incrimination, which she declined to invoke
in reliance on the protections afforded her by Martindell and the Protective Order.
This Court should (1) suppress all evidence the government obtained from
and any other evidence derived therefrom; or (2) suppress the April and July 2016 depositions
and all evidence derived therefrom; and (3) dismiss Counts Five and Six.
ARGUMENT
I. The government's violation of the Fourth Amendment requires suppression.
The Fourth Amendment provides: "The right of the people to be secure in their persons,
houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and
no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and
particularly describing the place to be searched, and the persons or things to be seized." U.S.
CONST. amend. IV. The "Fourth Amendment provides protection against a grand jury subpoena
duces tecum too sweeping in its terms 'to be regarded as reasonable." United States V. Dionisio,
410 U.S. 1, 11-12 (1973) (quoting Hale V. Henkel, 201 U.S. 43, 76 (1906), abrogated in part on
other grounds by Murphy V. Waterfront Comm'n of New York Harbor, 378 U.S. 52, 68 (1964)).
The government engages in a "search" for Fourth Amendment purposes when its conduct
encroaches on an individual's legitimate expectation of privacy. See Katz V. United States, 389
U.S. 347, 351 (1967) ("[T]he Fourth Amendment protects people, not places."). Absent an
exception to the warrant requirement, a governmental search is unconstitutional unless the
government conducts it under a warrant issued based on probable cause to believe a crime has
been committed and that evidence of the crime is likely to be found in the place searched.
2
EFTA00015308

=== Page 7 ===
Carpenter V. United States, 138 S. Ct. 2206, 2213 (2018) (holding that an "official intrusion into
[the] private sphere generally qualifies as a search and requires a warrant supported by probable
cause"). "[A] compulsory production of
private books and papers
is the equivalent of a
search and seizure-and an unreasonable search and seizure-within the meaning of the fourth
amendment." Boyd V United States, 116 U.S. 616, 634-35 (1886), overruling in part on other
grounds as recognized in Fisher V. United States, 425 U.S. 391, 407-08 (1976).
Finally, "The Fourth Amendment protects 'effects' as well as people from unreasonable
searches and seizures." United States V. Place, 462 U.S. 696, 716 (1983) (Brennan, J.
concurring). It thus "protects two different interests of the citizen-the interest in retaining
possession of property and the interest in maintaining personal privacy." Id. (cleaned up). "A
seizure threatens the former, a search the latter." Id. Like a search, a seizure is "per se
unreasonable within the meaning of the Fourth Amendment unless it is accomplished pursuant to
a judicial warrant issued upon probable cause and particularly describing the items to be seized."
Id. at 701; see Colorado V. Bannister, 449 U.S. 1, 3 (1980).
Here, the grand jury subpoena was unconstitutionally overbroad because it sought
production of
entire file and was therefore akin to a general warrant. Moreover,
there is no dispute the government did not establish probable cause to believe that
file contained evidence of a crime.
)
Nor is there a dispute that the government lacked a warrant.
)
Since the government had neither
probable cause nor a warrant, the
must be suppressed because the subpoena to
3
EFTA00015309

=== Page 8 ===
was in fact a Fourth Amendment search. And even if the government's conduct did not
amount to a search, it constituted a seizure, which likewise should have been supported by
probable cause and warrant.
A. The subpoena violated the Fourth Amendment because it was
unconstitutionally overbroad.
The subpoena to
was unconstitutionally overbroad, and this Court should
suppress all evidence produced in response.
"[A]n order for the production of books and papers may constitute an unreasonable
search and seizure within the 4th Amendment." Hale, 201 U.S. at 76. Because the Fourth
Amendment was drafted with a particular eye to the abuse of general warrants, id. at 71, a
subpoena that is "unreasonably overbroad" effects an unreasonable search under the Fourth
Amendment, In re Grand Jury Subpoena, JK-15-029, 828 F.3d 1083, 1088 (9th Cir. 2016). An
overbroad subpoena is "equally indefensible as a search warrant would be if couched in similar
terms." Id. (quoting Hale, 201 U.S. at 77). A subpoena is overbroad when the government fails
to make a "reasonable effort to request only those documents that are relevant and non-
privileged, consistent with the extent of its knowledge about the matter under investigation." Id.
Here, the government by its own admission made no effort-must less a reasonable
effort-to tailor and target the subpoena to
As the prosecutor said to
4
EFTA00015310

=== Page 9 ===
See Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, Ex. D, at 17
(emphasis added). The government's representations to
were, of course, false.
The government met with
before it issued the subpoena, it knew what was in
file and who was
, and it
nevertheless disclaimed any ability to narrowly tailor any subpoena. Given "its knowledge about
the matter under investigation," the government's failure to make any effort, much less a
"reasonable effort," to request "only those documents that are relevant and non-privileged,"
renders the subpoena overbroad and unconstitutional. See In re Grand Jury Subpoena, JK-15-
029, 828 F.3d at 1088.
So overbroad was the subpoena that
actually produced to the government
It is obvious why the Fourth Amendment requires suppression Id. at 1089. This type of
overbroad subpoena is exactly what the Fourth Amendment is designed to prohibit: searches that
invade "the privacies of life" from "arbitrary" power and "police surveillance" that is "too
permeating." See Carpenter, 138 S. Ct. at 2213 (quoting Smith V. Maryland, 442 U.S. 735, 740
(1979)). Otherwise, "when the government seeks all material of a broad generic type that a party
possesses-every piece of paper in a corporation's files, for example, or, as in this case," every
piece of paper in a
file, "a reasonable possibility that some of that material would be
relevant would suffice to validate the subpoena, no matter how vast its sweep, and no matter the
5
EFTA00015311

=== Page 10 ===
degree to which the subpoena would reach private material of no pertinence to the grand jury's
inquiry." See In re Grand Jury Subpoena, JK-15-029, 828 F.3d at 1089. The Fourth Amendment
does not allow such a sweeping search, which would be nothing but a modern-day general
warrant. Id. at 1088. 1 This Court should suppress all evidence the government obtained from the
subpoena to
B. The government's subpoena to
was an unconstitutional
warrantless Fourth Amendment search.
Apart from its overbreadth, the subpoena violated the Fourth Amendment because it
amounted to a warrantless search without probable cause.
The Fourth Amendment protects people, not places. Katz, 389 U.S. at 351. Thus, "when
an individual 'seeks to preserve something as private,' and [her] expectation of privacy is 'one
that society is prepared to recognize as reasonable,'
that official intrusion into that private
sphere generally qualifies as a search and requires a warrant supported by probable cause."
Carpenter, 138 S. Ct. at 2213 (quoting Smith, 442 U.S. at 740). This definition of a what
constitutes a "search" "seeks to secure 'the privacies of life' against "arbitrary power" and "to
place obstacles in the way of a too permeating police surveillance." Id. at 2214 (quoting Boyd,
116 U.S. at 630; United States V. Di Re, 332 U.S. 581, 595 (1948)). A "grand jury is
"without
power to invade a legitimate privacy interest protected by the Fourth Amendment." United
States V. Thomas, 736 F.3d 54, 61 (1st Cir. 2013) (quoting United States V. Calandra, 414 U.S.
338, 346 (1974)).
1 It is for this reason that this Court should grant Maxwell's Motion for Discovery of every grand
jury subpoena. Without being able to examine the grand jury subpoenas, Maxwell cannot evaluate
whether other subpoenas issued by the grand jury in connection with this case are unconstitutionally
overbroad, as the subpoena to
is.
6
EFTA00015312

=== Page 11 ===
Maxwell had a legitimate expectation of privacy in her
2
because
she reasonably sought to preserve them as private. Both of her
were
confidential under the Protective Order, which prohibited
from sharing
them with third parties, including law enforcement. The Protective Order deliberately excluded a
law enforcement exception. While the Protective Order did not apply to evidence produced at
trial, the parties settled the defamation action before trial, conclusively establishing the privacy
of Maxwell's deposition testimony. Indeed, under the plain terms of the Protective Order,
were required to return or destroy all confidential information at the
conclusion of the case, including Maxwell's deposition transcripts.
refused to do
so although ordered to do so by Judge Sweet.
In its application to
, the government
Not only did the government misunderstand how the Protective Order worked,
but its argument also supports rather than undermines Maxwell's legitimate expectation of
privacy in her deposition transcripts.
To be sure, the Protective Order did not apply to evidence produced at trial. That is
entirely unremarkable, however, because trials are open to the public and the press. What matters
is that the civil case did not go to trial; it settled before trial, and under the Protective Order's
terms,
2 Not to mention all the other material she designated as "Confidential" under the Protective
Order.
3 Ascribing a legitimate expectation of privacy to
also fits
Martindell's admonition that the government may not "insinuate itself into a private civil lawsuit between
others." 594 F.2d at 294.
7
EFTA00015313

=== Page 12 ===
including Maxwell's
and not to share Confidential information with law
enforcement.
Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, Ex. F, at 11
(emphases in original).
Maxwell thus had a reasonable expectation of privacy in her
and
everything else she designated as "Confidential" under the Protective Order. Obtaining that
confidential material by subpoena therefore amounted to a search under the Fourth Amendment.
Because the government had neither probable cause nor a warrant, this Court should suppress the
and all material Maxwell designated as Confidential.
1. The third-party doctrine does not compel a different result.
It is irrelevant that Maxwell's
were in the possession of
and not her own attorneys. The third-party doctrine does not apply here because
4 This argument adheres to Martindell's holding that the government there should have either
moved to intervene or issued a subpoena to obtain the
For one thing, the Fourth
Amendment was not at issue in Martindell, so the Court had no occasion to decide whether a warrant
might have been required. For another, Martindell does not speak to what showing would have been
required for the issuance of a subpoena, probable cause or something less. Even if a warrant weren't
required here, a showing of probable cause was. See People V. Mason, 989 P.2d 757, 760 (Colo. 1999)
(noting jurisdictions that recognize an expectation of privacy in subpoenaed materials and that require a
subpoena duces tecum of such records to be supported by probable cause). Finally, of course, the
government didn't comply with Martindell because it never gave Maxwell notice and an opportunity to
quash the subpoena and to challenge the government's misrepresentations through the adversary process.
8
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=== Page 13 ===
Maxwell did not voluntarily share anything with
and because every other circumstance
supported Maxwell's expectation that her
would be private.
The Supreme Court has held that "a person has no legitimate expectation of privacy in
information [she] voluntarily turns over to third parties." Smith, 442 U.S. at 743-44. "That
remains true 'even if the information is revealed on the assumption that it will be used only for a
limited purpose." Carpenter, 138 S. Ct. at 2216 (quoting United States V. Miller, 425 U.S. 435,
443 (1976)).
In Smith V. Maryland, the Court ruled that the government's use of a pen register-a
device used by telephone companies to record the outgoing phone numbers dialed on a landline
telephone-was not a search. By placing calls from his landline, the Court reasoned, Smith
"voluntarily conveyed" the dialed numbers to the telephone company by "expos[ing] that
information to its equipment in the ordinary course of business." 442 U.S. at 744. The Court held
that Smith has "assumed the risk" that the telephone company's records "would be divulged to
police." Id. at 745.
Similarly, in United States V. Miller, the Court ruled that the government could subpoena
an individual's bank records, including several months of canceled checks, deposit slips, and
monthly statements. The Court explained that because the checks were "not confidential
communications but negotiable instruments to be used in commercial transactions," and because
the bank statements contained information "exposed to [bank] employees in the ordinary course
of business," Miller had only a limited expectation of privacy. 425 U.S. at 442. The Court
determined that Miller had "take[n] the risk, in revealing his affairs to another, that the
information [would] be conveyed by that person to the Government." Id. at 443.
9
EFTA00015315

=== Page 14 ===
Neither Miller nor Smith supports a conclusion that Maxwell had anything but a
legitimate and reasonable expectation of privacy in her
First, Maxwell did
not "voluntarily convey"
sued her, not the other way around.
Moreover, Maxwell declined to answer
None of this was voluntary.
Second, Maxwell's expectation of privacy in her
is not limited in
the way Miller's expectation of privacy was limited in his bank records. To the contrary, both
Maxwell's
were confidential under the Protective Order. And while the Protective
Order did not apply to evidence produced at trial, the case settled before trial, thereby confirming
Maxwell's legitimate expectation that the
would not be shared outside the
attorneys working in the case and, if necessary, the district court.
Third, Maxwell reasonably understood that the
would not
be shared with the government.
proposed a law enforcement exception to the Protective
Order's confidentiality requirement, but Maxwell rejected the exception and the district court
never adopted it. Unlike in Smith and Miller, Maxwell did not "assume the risk" that her
would be divulged to the government.
Had the government obtained the
from Maxwell's attorneys, there
would be no question that the government's conduct would constitute a Fourth Amendment
search. "[C]lients of an attorney maintain a legitimate expectation of privacy in their client files."
DeMassa V. Nunez, 770 F.2d 1505, 1506 (9th Cir. 1985); see Doe V. Broderick, 225 F.3d 440,
450-52 (4th Cir. 2000) (holding that detective's examination of a patient file held by a
methadone clinic was a search and, without probable cause, violated the patient's Fourth
10
EFTA00015316

=== Page 15 ===
Amendment rights); see also People V. Gutierrez, 222 P.3d 925, 936 (Colo. 2009) (concluding
that a taxpayer has a reasonable expectation of privacy in information conveyed to his tax
preparer because "state and federal laws
shield a taxpayer's return from unfettered access by
government officials"). Because she did not voluntarily offer
, and
because she reasonably believed
was and would remain private under the
Protective Order, Maxwell had a legitimate and reasonable expectation of privacy in her
even though the government obtained them from a third party other than
her attorneys. See In re Grand Jury Subpoena, JK-15-029, 828 F.3d at 1090 ("DAS's current
possession of [Kitzhaber's] emails does not vitiate that claim. The Fourth Amendment protects
people, not places. Kitzhaber's interests therefore attach to the things seized, not merely to the
place where they are located." (cleaned up)).
C. The government's subpoena to
was an unconstitutional
Fourth Amendment seizure.
Although Fourth Amendment challenges typically involve "the subsequent search of the
container rather than to its initial seizure by the authorities,
a seizure of personal property is
per se unreasonable" under the "Fourth Amendment unless it is accomplished pursuant to a
judicial warrant issued upon probable cause and particularly describing the items to be seized."
Smith, 462 U.S. at 701-02. Here, the government
The government did not obtain a warrant, nor did it
establish probable cause for the seizure. For this additional reason, this Court should suppress the
and all material Maxwell designated as confidential.
II. The government's violation of Martindell requires suppression.
By issuing a
the government circumvented the Second Circuit's
11
EFTA00015317

=== Page 16 ===
decision in Martindell V. International Telephone & Telegraph Corp. and violated Maxwell's
rights.
In Martindell, the government tried to obtain deposition transcripts of twelve individuals
deposed in a private shareholders' derivative lawsuit. 594 F.2d at 292-93. All twelve depositions
were taken "pursuant to a court-approved stipulation to the effect that the depositions should be
treated as confidential and used solely by the parties for prosecution or defense of the action." Id.
at 292. Without seeking to intervene, and without serving a subpoena or warrant, the government
called and then wrote to the district court to request access to the deposition transcripts. Id. at
293. The government claimed that the deposition transcripts were relevant to its investigation of
perjury, subordination of perjury, and conspiracy related to the 1970 presidential election in
Chile. Id. The government, "moreover, feared that unless it could obtain the deposition
transcripts, it would be unable to secure statements from the witnesses because they would claim
their Fifth Amendment rights in any investigative interviews." Id. The district court denied the
government's request, "holding that the deposition testimony had been given in reliance upon the
protective order, thus rendering unnecessary invocation by the witnesses of their Fifth
Amendment rights, that the requested turnover would raise constitutional issues, and that
principles of fairness mandated enforcement of the protective order." Id. The government
appealed, and the Second Circuit affirmed.
The Second Circuit was blunt in explaining the government's missteps:
The government may not simply by picking up the telephone or writing a letter
to the court (as was the case here), insinuate itself into a private civil lawsuit
between others. The proper procedure, as the government should know, was either
to subpoena the deposition transcripts for use in a pending proceeding such as a
grand jury investigation or trial, in which the issue could be raised by motion to
quash or modify the subpoena, see Rule 17(c), or to seek permissive intervention
in the private action pursuant to Rule 24(b), for the purpose of obtaining vacation
or modification of the protective order.
12
EFTA00015318

=== Page 17 ===
Id. at 294. Either avenue, explained the Court, would provide the real party in interest notice of
the government's request and an opportunity to be heard, either by moving to quash the
subpoena or opposing intervention and modification of the protective order. Id.
The Court also rejected the government's argument that the district court was too
solicitous of the witnesses' Fifth Amendment rights. Id. at 295. According to the Government,
the witnesses were under no compulsion to testify, and having given testimony, they voluntarily
waived any Fifth Amendment right they may have had. Id. But as the Second Circuit explained,
the government's argument ignored the reality of civil litigation:
Unless a valid Rule 26(c) protective order is to be fully and fairly enforceable,
witnesses relying upon such orders will be inhibited from giving essential
testimony in civil litigation, thus undermining a procedural system that has been
successfully developed over the years for disposition of civil differences. In short,
witnesses might be expected frequently to refuse to testify pursuant to protective
orders if their testimony were to be made available to the government for criminal
investigatory purposes in disregard of those orders.
Id. at 295-96. The Court thus held:
[A]bsent a showing of improvidence in the grant of a Rule 26(c) protective order
or some extraordinary circumstance or compelling need, none of which appear here,
a witness should be entitled to rely upon the enforceability of a protective order
against any third parties, including the Government, and that such an order should
not be vacated or modified merely to accommodate the government's desire to
inspect protected testimony for possible use in a criminal investigation, either as
evidence or as the subject of a possible perjury charge.
Id. at 296.
Maxwell did not even know the government had her
until after she was
13
EFTA00015319

=== Page 18 ===
indicted, and she didn't know for a month more jus
Martindell has been binding Second Circuit law for more than forty years, and the
government's violation of its holding is no trivial matter
In Palmieri V. State of New York, the federal magistrate issued two sealing orders
protecting the confidentiality of settlement discussions of a private antitrust case. 779 F.2d 861,
863-64 (2d Cir. 1985). Because the subject matter of the antitrust case overlapped with an
ongoing state criminal antitrust case, the state Attorney General moved to intervene in the private
antitrust case, to modify the seal orders, to access the settlement material, and to present the
material and testimony to a state grand jury. Id. at 862. The district court granted the Attorney
General's request, but the Second Circuit, applying Martindell, reversed. Id. The Second Circuit
recognized that the state Attorney General, like the federal government, "enjoys a similarly
privileged position with respect to its investigatory powers." Id. at 866. Those powers, in turn,
"raise[d] a rebuttable presumption against modification of the orders." Id. Indeed, given the
parties' reliance on the sealing orders, the Attorney General's "burden [was] heavier than it
might otherwise be." Id. at 865.
14
EFTA00015320

=== Page 19 ===
Here, the government did not even attempt the Martindell process the Attorney General
attempted in Palmieri.
III. The government's violation of the Fifth Amendment requires suppression.
The Fifth Amendment provides: "No person
shall be compelled in any criminal case
to be a witness against himself." U.S. CONST. amend. V. For three separate reasons,
violates the Fifth Amendment.
First, the Fifth Amendment "proscribe[s] the compelled production of
a Testimonial
Communication that is incriminating." Fisher, 425 U.S. at 408; see Dionisio, 410 U.S. at 11
("The grand jury cannot require a witness to testify against himself."). The subpoena to
contravenes this proscription because it literally "compels production" of Maxwell's
incriminating testimony
Second, "a compulsory production of the private books and papers
[also] is
compelling
him to be a witness against himself, within the meaning of the fifth amendment."
Boyd, 116 U.S. at 634-35. Even if the subpoena does not literally require Maxwell to "testify
against herself," Dionisio, 410 U.S. at 11, Maxwell's
were private and
confidential under the Protective Order. Supra Part I.B. Compelling production of these
"private" papers is itself a Fifth Amendment violation.
Third, the government's circumvention of Martindell unconstitutionally burdens
Maxwell's Fifth Amendment rights.
But Martindell protects Maxwell from
the government's conduct, and it authorized her to give
under the shield of
the Protective Order without worrying whether the government could "insinuate itself" into the
15
EFTA00015321

=== Page 20 ===
case and use her own words against her. 594 F.2d at 294. The Fifth Amendment would mean
nothing if an individual were told by a district court that she need not invoke its protections
because the government could not use her testimony against her-or at least could not do so
without notice and an opportunity to be heard-only to find out that the testimony she offered
with the district court's blessing was the primary evidence against her in a criminal case and the
basis of perjury charges.
That is the lesson of United States V. Oshatz, in which this Court quashed a government
subpoena issued to a court reporter for a transcript of a deposition offered by the defendant in a
civil proceeding. 700 F. Supp. 696, 697 (S.D.N.Y. 1988). Oshatz (who had been indicted at the
time of his deposition) was deposed and did not invoke his Fifth Amendment privilege against
self-incrimination on "the understanding that a protective order would preserve his Fifth
Amendment rights." Id. at 699. Applying Martindell, this Court quashed the government's
subpoena and refused to release the deposition transcript because the "government [had] not
argued that the protective order was improvidently granted or that there [were] some
extraordinary circumstances or compelling need." Id. at 701.
Here, as in Oshatz, Maxwell was deposed on "the understanding that a protective order
would preserve" the confidentiality of her testimony. And even though Maxwell had not been
indicted at the time of her depositions, the threat of an investigation was obvious, and that threat
was the very reason the Protective Order deliberately excluded a law-enforcement exception.
(Moreover, Maxwell moved the court to require
to disclose any law enforcement
investigation of which she was aware.) As in Oshatz, the Protective Order was designed to
preserve Maxwell's Fifth Amendment rights. Where this Court in Oshatz granted a motion to
quash, here it should grant a motion to suppress.
16
EFTA00015322

=== Page 21 ===
For these reasons, this Court should suppress the
under the Fifth
Amendment.
Conclusion
For these reasons, this Court should: (1) suppress all evidence the government obtained
from
and any other evidence derived therefrom; or (2) suppress the April and July
2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six.
Maxwell requests an evidentiary hearing on this Motion.
Dated: January 25, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Denver, CO 80203
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Attorneys for Ghislaine Maxwell
17
EFTA00015323

=== Page 22 ===
Certificate of Service
I hereby certify that on January 25, 2021, I served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the Memorandum of Ghislaine Maxwell in Support
of Her Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress
All Evidence Obtained from the government's Subpoena to
and to Dismiss Counts
Five and Six upon the following:
U.S. Attorney's Office, SDNY
New York, NY 10007
s/ Christian R. Everdell
18
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017037.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: use this version
Date: Thu, 14 May 2020 18:37:57 +0000
Attachments: 2020-05-08,
From:
Sent: Thursday, May 14, 2020 14:05
To:
Subject: use this version
All done-this should have everything. Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
EFTA00017037


c1: EFTA00014685
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014685.pdf
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=== Page 1 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Confidential
Page 1 of 9
JEFFREY EPSTEIN
Asset Account Portfolio
September 1- September 30, 2002
Table of Contents
Page
Portfolio Summary
2
Cash and Short Term
3
Trade Activity
5
Account Transactions
6
Account Officers
Service Specialist: RILEY/HORNBECKER
000000.0000.000000.000.000000000000000 00
JEFFREY E EPSTEIN
C/O FINANCIAL TRUST COMPANY
ATTN: JEANNE BRENNAN
ST THOMAS VI 00802
GOVERNMENT
EXHIBIT
504
$2 20 Cr. 330 (AJN)
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005505
Chase
EFTA00014685

=== Page 2 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 2 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Overview
Market Value USD
Market Value USD
Tax
Estimated Annual
Yield
Portfolio Summary
Sep 30
Aug 31
Cost USD
Income USD
*
Cash & Short Term
6,838,687.24
14,816,643.79
6,838,687.24
109,416.12
1.6
Total
6,838,687.24
14,816,643.79
6,838,687.24
109,416.12
1.6
Except for the Deposit Account (if elected). and the cash in your Asset Account which
are insured deposits with JPMCB none of the investments referred to in this statement
Accrued Income
11,992.75
22,043.45
of your Asset Account including mutual funds are FDIC insured or bank deposits
Total Portfolio Value
6,850,679.99
14,838,687.24
obligations of or guaranteed by JPMCB or any of its bank or thrift affiliates (unless
otherwise indicated) Such securities and other investments are subject to investment
risks including possible loss of the principal amount invested See "Important
Information about your JPMSI Brokerage Account" at the end of this Asset Account
Portfolio
Asset Allocation
Income Summary
100% Cash and Short Term
This Period USD
Year to Date USD*
Taxable Interest
949.99
949.99
U.S. Tax Exempt Dividends
21,093.46
21,475.74
Total
22,043.45
22,425.73
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005506
Chase
EFTA00014686

=== Page 3 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 3 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Cash and Short Term
Summary by Maturity
Current Market Value
Estimated Annual Income
USD
USD
Cash
957.08
12.44
Less Than 3 Months
6,837,730.16
109,403.68
Total
6,838,687.24
109,416.12
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 %
Cash
JP MORGAN TAX FREE MONEY MARKET
USD
957.08
1.00
1.00
957.08
957.08
12.44
1.30
PREMIER CLASS SWEEP FUND (92)
0.83
(SWEEP DEADLINE IS 11:30 AM EST)
7-Day Annualized Yield: 1.27%
Short Term by Maturity
JP MORGAN TAX FREE MONEY MARKET
USD
6,837,730.16
1.00
1.00
6,837,730.16
6,837,730.16
109,403.68
1.60
FUND INSTITUTIONAL SHARE CLASS
11,991.92
(FUND 840)
7-Day Annualized Yield: 1.52%
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005507
Chase
EFTA00014687

=== Page 4 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 4 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Cash and Short Term by Type
continued
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 %
Total Cash and Short Term
6,838,687.24
6,838,687.24
0.00
109,416.12
1.60
11,992.75
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-00005508
Chase
EFTA00014688

=== Page 5 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 5 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
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
Capital gains and losses on sales with missing or incomplete tax cost are identified with N/A.
Trade Activity by Type
Trade
Settlement
Realized
Date
Date
Type
Description
Currency
Quantity
Price/Unit
Market Cost/Proceeds
Tax Cost
Gain/Loss USD
Settled
Aug 30 Sep 3
Purchase
JP MORGAN TAX FREE MONEY MARKET
USD
21,086.37
1.00
-21,086.37
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
Sep 10 Sep 10 Sale
JP MORGAN TAX FREE MONEY MARKET
USD
-2,000,000
1.00
2,000,000.00
- 2,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
Sep 16 Sep 16 Sale
JP MORGAN TAX FREE MONEY MARKET
USD
- 1,000,000
1.00
1,000,000.00
1,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
Sep 18 Sep 18 Sale
JP MORGAN TAX FREE MONEY MARKET
USD
-5,000,000
1.00
5,000,000.00
-5,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005509
Chase
EFTA00014689

=== Page 6 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 6 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Account Transactions
Cash Activity Summary
Amount this
Amount Year
Period USD
to Date USD*
Beginning Balance
.00
Credits
Dividends
21,093.46
21,475.74
Taxable Interest
949.99
949.99
Sweep Account Sales
48,998.65
Sales, Maturities, Redemptions
8,000,000.00
18,000,000.00
Miscellaneous Receipts
24,767,645.14
Debits
Sweep Account Purchases
-957.08
- 1,339.36
Purchases of Securities
-21,086.37
-24,837,730.16
Miscellaneous Disbursements
- 8,000,000.00
- 18,000,000.00
Ending Balance
.00
"Year to date information is calculated on a calendar year basis.
Activity by Date
Settlement
Date
Type
Quantity Description
Amount USD
Sep 3
Dividend
JP MORGAN TAX FREE MONEY MARKET
7.09
PREMIER CLASS SWEEP FUND (92)
(SWEEP DEADLINE IS 11:30 AM EST)
Sep 3
Interest
INTEREST FOR AUG. @ 1.4% ON NET
949.99
AVERAGE COLLECTED BALANCE
$798,956.29
AS OF 09/01/02
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005510
Chase
EFTA00014690

=== Page 7 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 7 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Activity by Date
continued
Settlement
Date
Type
Quantity Description
Amount USD
Sep 3
Dividend
JP MORGAN TAX FREE MONEY MARKET
21,086.37
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
Sep 3
Purchase
21,086.37 JP MORGAN TAX FREE MONEY MARKET
-21,086.37
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
INCOME DIVIDEND
REINVESTED @ $1.00
J.P.MORGAN SECURITIES INC AS AGENT
TRADE DATE 08/30/02
Sep 3 Purchase
957.08 JP MORGAN TAX FREE MONEY MARKET
-957.08
PREMIER CLASS SWEEP FUND (92)
(SWEEP DEADLINE IS 11:30 AM EST)
Sep 10 Sale
-2,000,000
JP MORGAN TAX FREE MONEY MARKET
2,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
J.P.MORGAN SECURITIES INC AS AGENT
@1.00
TRADE DATE 09/10/02
Sep 10 Misc. Disbursement
TRANSFERRED BY WIRE TO
- 2,000,000.00
PALM BEACH NATL BK & TR CO
FAO JEFFREY EPSTEIN
LETTER FROM CLIENT
Sep 16 Sale
-
- 1,000,000
JP MORGAN TAX FREE MONEY MARKET
1,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
J.P.MORGAN SECURITIES INC AS AGENT
@1.00
TRADE DATE 09/16/02
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005511
Chase
EFTA00014691

=== Page 8 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 8 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
Activity by Date
continued
Settlement
Date
Type
Quantity Description
Amount USD
Sep 16
Misc. Disbursement
TRANSFERRED BY WIRE TO
- 1,000,000.00
PALM BEACH NATL BK & TR CO
FAO JEFFREY EPSTEIN
LETTER FROM CLIENT
Sep 18 Sale
-5,000,000 JP MORGAN TAX FREE MONEY MARKET
5,000,000.00
FUND INSTITUTIONAL SHARE CLASS
(FUND 840)
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 09/18/02
Sep 18 Misc. Disbursement
TRANSFERRED BY WIRE TO
- 5,000,000.00
PALM BEACH NATL BK & TR CO
FAO GHISLAINE MAXWELL
LETTER FROM CLIENT
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005512
Chase
EFTA00014692

=== Page 9 ===
09
JPMorgan Chase Bank
2002
New York, NY 10154-1002
JPMorgan Private Bank
Account Number:
Asset Account Portfolio
Page 9 of 9
JEFFREY EPSTEIN
September 01, 2002 - September 30, 2002
in Case of Errors or Questions About Your Electronic Transfers.
Contact your Morgan Teamat one of the telephone numbers on the front of this statement 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 explainas clearly as
you can why you believeit 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 your debit card or for internationa/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: JPMorgan,
Private Bank, 500 Stanton Christiana Road, 1/OPS3 Newark, DE 19713-2107 We must hear from you no later than 60 days after the statement on which the error or problem appeared is sent You can contact your client service specialist 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) a 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 JPMorgan Funds or The JPMorgan Institutional Funds or The American Century Funds
J.P. Morgan Funds Distributor, Inc. is the distributor of the J.P. Morgan Funds and American Century Investment Services Inc. is the distributor of the American Century Funds. JPMorgan Investment Management Inc. and American Century Investment Management serve as
investment advisors to their respectivefund 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 original cost. While the
money market funds seek to maintain a stable net asset valueof $1.00 per share, there is no assurancethat 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
If you have chosen one of the sweep mutual funds, you are notified that positions in the Prime Money Market Sweep Fund represent holdings in the JPMorgan Prime Money Market Fund; positions in the Federal Money Market Sweep Fund
represent holdings in the JPMorgan Federal Money Market Fund and positions in the Tax Exempt Money Market Sweep Fund represent holdings in the JPMorgan Tax Exempt Money Market Fund
JPMorgan Private Bank is the marketing name for the private banking business conducted by J.P. Morgan Chase & Co. through its subsidiaries worldwide including JPMorgan Chase Bank J.P. Morgan Trust Company N.A. and J.P. Morgan Securities Inc.
JPMSI is a member of the Securities Investor Protection Corporation (SIPC), a not-for-profit membership corporation funded by broker-dealers registered with the Securities and Exchange Commission Securities and cash held for a customer account at
JPMSI are protected up to an amount of $50,000,000 The first $500,000 of protection which includes up to $100,000 of protection for cash, is provided by SIPC The balance of the protection which includes up to an additional $900,000 of protection
for cash, is provided by a separate Excess Securities Bond issued by Travelers Casualty and Surety Company of America. This SIPC and excess SIPC protection does not protect against losses from fluctuations in the value of the securities Assets held in
custody by JPMCB are not subject to SIPC coverage.
Confidential Treatment Requested by JPMorgan
JPM-SDNY-00005513
Chase
EFTA00014693


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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
November 20, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing witness materials, government exhibits, and discovery
pertinent to Ghislaine Maxwell (02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
/s
Assistant United States Attorneys
EFTA00014654


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=== Page 1 ===
To:
ghislaine maxwell
From:
Subject:
see you in new york
Sent:
Sat, 7 Feb 2004 15:50:59 -0600
<x-flowed>
hi ghislaine,
it was good to hear from you the other day. i thought i'd fill you in
on my situation and see how we can work together.
i am still dancing, pilates-ing and teaching. i am very interested to
keep training jeffery as we work well together and i enjoy working with
him.
i understand he likes to work with a variety of beautiful, talented
young women and i think that training with lots of people can be a very
good thing. i understand what i am looking for in other people to
train / work with him, and it's quite a tall order, which is why i know
that you need some help you find people. they don't come along every
day.
i need to use my time effectively; to continue with my dance classes,
learning, training and also earning money to pay for it all.
if i am looking for girls i will need to go to a wide variety of
classes, whereas at the moment i tend to stick to the one's i like.
(not necessarily the one's to find suitable girls).
so if you want me to be actively looking, then we will need to reach a
financial arrangement as this will be my job. or if you just want me to
let you know if i come across someone suitable on my travels, then what
will you pay me for this? as i am effectively 'doing myself out of a
job'.
i would just like to have a good idea of where i stand, and if i will
be getting more work from you, or if you can put me in touch with other
people who may want a trainer. or if i can make 'looking for other
people' my main source of income.
as i am here properly now, i have bills and rent to pay, i need to find
something somewhat stable.
i can be available to travel, but if i am 'on call' i need to know and
be paid accordingly.
i have a couple of girls in mind, so let me know what arrangement we
will have, and i will do my best to help.
i am appreciative of any work you can throw my way.
i look forward to seeing you when you're back in nyc. give my best to
rainy england!
love
X
EFTA00014592

=== Page 2 ===
p.s. do you want a lesson?
</x-flowed>
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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re: Epstein search materials for upload and privilege review
Date: Fri, 21 Feb 2020 22:04:28 +0000
Moving may be an issue, PAE had trouble releasing the data because they were so voluminous.
On Feb 21, 2020, at 4:55 PM,
)
wrote:
Ah, possibly it's the "2020-01-23" folder under Subpoena Returns? If so,
can we please (1) move that to under the
Search Warrant Returns folder, and (2) if at all possible, combine the 37 different subfolders into one? There doesn't
appear to be any distinction between all of those folders so I don't think there's any utility in having so many subgroups.
But let us know if (2) is a problem and happy to discuss.
From:
Sent: Friday, February 21, 2020 16:53
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
I think they are in the Subpoena Returns folder, which I thought was strange. I'm heading to
now but will log in
after that to find them.
From:
Sent: Friday, February 21, 2020 4:32 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
just tried calling but didn't catch you - I don't see where these are located in Relativity? I think they should be
under "Search Warrant Returns" but I don't see them there (or anywhere else under the Epstein overall folder). Let me
know if I've just missed them, which is entirely possible, or if they're not accessible to us yet? Thank you!
From:
Sent: Thursday, February 20, 2020 21:12
To:
is
EFTA00016912

=== Page 2 ===
Cc:
is
Subject: Re: Epstein search materials for upload and privilege review
The NP folder has been released.
On Feb 20, 2020, at 2:28 PM,
wrote:
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
From: Korologos,
(USANYS)
Sent: Thursday, February 20, 2020 11:42 AM
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
Thanks,
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
is
EFTA00016913

=== Page 3 ===
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be
grateful - and we'll plan to get it to
asap once we have access.
thanks,
From:
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection
with the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied
here)? I've left the hard drive with the materials on your chair. (And if we could please get that hard drive back once
the materials are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will
also be coming shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with
Epstein search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
<STR_Epstein_Privilege Terms_02.14.2020.pdf>
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=== Page 1 ===
From:
To:
)"
Subject: Epstein calls
Date: Thu, 29 Aug 2019 14:01:18 +0000
Embedded: Voice_Message_Attached_from_4077619659
Voice_Message_Attached_from_3323318056_-
Voice_Message_Attached_from_3473617139_
Voice_Message_Attached_from_8438607398_-
Voice_Message_Attached_from_2018861727_
Voice_Message_Attached_from_2018861727_
Voice_Message_Attached_from_2018861727_
Voice_Message_Attached_from_2123210698_-
Voice_Message_Attached_from_41794855559_
Voice_Message_Attached_from_3107213688_-
Voice_Message_Attached_from_9542403530_-
Voice_Message_Attached_from_3026028619_-
Voice_Message_Attached_from_7025218198_-
I just want to be sure that you received all of these previous calls.
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=== Page 1 ===
From: "NYSReportServer@usa.doj.gov" <NYSReportServer@usa.doj.gov>
To:
Subject: Child Exploitation & Porn Update Report III
Date: Tue, 23 Jul 2019 20:48:58 +0000
Attachments: Child_Exploitation_&_Porn_Update_Report_IILpdf
Attached is the Child Exploitation & Porn Update Report III for Project Safe Childhood.
Chiefs and Project Safe Childhood Coordinator, please remind the assigned AUSA to make updates in their
cases. Thanks!
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=== Page 1 ===
From:
To:
Cc:
Subject: Times: Lawsuit Claims Epstein Trafficked Girls in Caribbean Until 2018
Date: Wed, 15 Jan 2020 20:20:25 +0000
Inline-Images: image001.jpg; image006.jpg; image007.jpg
https://www.nytimes.com/2020/01/15/nyregion/jeffrey-epstein-virgin-islands.html
Lawsuit Claims Epstein Trafficked Girls in
Caribbean Until 2018
The attorney general of the Virgin Islands says Mr. Epstein and his associates used a database to track
victims as young as 11 years old.
A new lawsuit significantly expanded the scope of wrongdoing in which Mr. Epstein was said to have
engaged. Credit New York State Sex Offender Registry, via Associated Press
EFTA00016836

=== Page 2 ===
By Ali Watkins
Jan. 15, 2020Updated 2:41 p.m. ET
New evidence shows Jeffrey Epstein sexually abused and trafficked hundreds of young women and
girls on his private Caribbean island, some as recently as 2018, significantly expanding the scope of his
alleged conduct, a top law enforcement official said in a lawsuit filed on Wednesday.
Mr. Epstein, a wealthy financier who died by suicide in a Manhattan jail last year, was bringing girls as
young as 11 and 12 to his secluded estate in the Virgin Islands, known as Little Saint James, and kept a
computerized database to track the availability and movements of women and girls, the lawsuit said.
The lawsuit, which was filed by Denise N. George, the attorney general of the Virgin Islands,
broadened the dimensions of the wrongdoing in which Mr. Epstein was said to have engaged. He had
been charged by Manhattan prosecutors in July with sexually exploiting dozens of women and girls in
New York and Florida, but they did not point to any actions beyond 2005.
In August, Mr. Epstein hanged himself at the Metropolitan Correctional Center, where he was being
held awaiting trial on federal sex trafficking and conspiracy charges. Prison guards had not checked on
him for hours on the night he died, and the circumstances surrounding his death are now the subject
of at least three federal investigations.
In the weeks before Mr. Epstein killed himself, he and his lawyers vigorously denied the criminal
charges. His lawyers had previously said he had been law-abiding since his 2008 conviction in Florida
for solicitation.
The suit was filed against Mr. Epstein's estate and seeks the forfeiture of Little Saint James and Mr.
Epstein's second private island, Great Saint James, as well as the dissolution of numerous shell
companies he established in the territory that officials have said acted as fronts for his sex trafficking
enterprise.
As part of its policies, the government of the Virgin Islands could take any assets recovered from Mr.
Epstein's estate and consider disbursing them to women and girls who were victimized by him in the
region, Ms. George said.
The new accusations - which draw both from independent investigations by Ms. George's office and
court documents from cases across the country - argue that Mr. Epstein ran a decades-long sex
trafficking scheme that had a primary nexus in the Virgin Islands.
Continue reading the main story
EFTA00016837

=== Page 3 ===
Image
Denise N. George, the attorney general of the Virgin Islands, is suing the estate of Jeffrey Epstein, a
wealthy financier. Credit Gabriella N. Baez for The New York Times
EFTA00016838

=== Page 4 ===
"Epstein clearly used the Virgin Islands and his residence in the U.S. Virgin Islands at Little Saint
James as a way to be able to conceal and to be able to expand his activity here," Ms. George said.
The suit underscores the legal complications of reckoning with such wide-reaching crimes as those Mr.
Epstein is said to have committed. Ms. George's suit is the first filed against the estate by a government
entity, but it joins a field of similar claims filed by more than a dozen women.
It remains unclear how Mr. Epstein's assets, which are valued at about $500 million, could be
allocated.
"We don't have a long history of figuring out what to do in cases of human trafficking," said Bridgette
Carr, the director of the Human Trafficking Clinic at the University of Michigan Law School, who
consulted with Ms. George's team on the case. "I think this litigation and the courts are just trying to
come up with the best, imperfect solution."
Mr. Epstein's executor, Darren K. Indyke, could not immediately be reached for comment.
Ms. George said she believed the case could chip away at the region's reputation as a notorious haven
for the rich and powerful.
"We will not remain complacent, and we will enforce our laws whatever way we can," Ms. George said.
"It doesn't matter the social status of the person. It's that the laws apply equally."
Image
A property on the island of Little Saint James, a private estate where Mr. Epstein is alleged to have
trafficked hundreds of girls. Credit Gabriella N. Baez for The New York Times
ADVERTISEMENT
Continue reading the main story
The court documents said that Mr. Epstein operated with impunity for years at Little Saint James and
Great Saint James, which he obtained through a straw purchaser in 2016.
As recently as July 2018, Mr. Epstein refused to permit an investigator from the Virgin Island's
Department of Justice to enter Little Saint James, claiming the island's dock was his "front door,"
according to the lawsuit. The investigator was doing routine monitoring of Mr. Epstein because he was
a registered sex offender.
Mr. Epstein's victims included aspiring models from South America, according to court documents.
EFTA00016839

=== Page 5 ===
Mr. Epstein used a ring of associates to rotate the women and girls in and out of sexual servitude,
using fraudulent modeling visas to transport them across state lines and international borders, the
lawsuit said. He tracked their availability and proximity using the database, court documents said.
The suit also said air traffic controllers in the Virgin Islands observed Mr. Epstein leaving his private
plane in 2018 with girls who looked as young as 11.
In one undated incident detailed in the lawsuit, a 15-year-old girl attempted to swim off Mr. Epstein's
island and escape after she was forced to engage in sex acts with Mr. Epstein and others. The girl was
found, and held captive on the island after he confiscated her passport, the suit said.
Prosecutors in New York have said their investigation has continued and anyone who helped Mr.
Epstein could face criminal charges.
In addition, the lawsuit said, Mr. Epstein embarked on several illegal construction projects at Great
Saint James, which caused damage to native coral and wildlife.
ADVERTISEMENT
Continue reading the main story
The more than a dozen women who have filed lawsuits against Mr. Epstein's estate in New York City
since his death have accused him of exploiting and sexually abusing them when they were young
women and girls, according to court documents. Many are seeking financial compensation.
The lawsuit in the Virgin Islands appears to be the first filed against the estate in that jurisdiction. Mr.
Epstein maintained his legal permanent residence - and his estate - there. He hastily filed his will in
a Virgin Islands court just days before he killed himself.
Ms. George's lawsuit also seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr.
Epstein's vast wealth into a victim's compensatory fund. Mr. Indyke's proposal, which is currently
being litigated in a separate Virgin Islands case, imposes confidentiality on any claimants, Ms. George
said.
"The estate continues to engage in a course of conduct aimed at concealing the criminal activities of the
Epstein enterprise," the lawsuit said.
In a statement when that fund was first announced, Mr. Indyke said it would give victims "the
opportunity to obtain appropriate compensation and to be heard and treated with compassion, dignity
and respect."
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Q&A
Date: Sat, 27 Nov 2021 17:38:41 +0000
Attachments:
Direct_Examination_v4.docx
Here's the current draft. Still pretty rough unfortunately. Would really appreciate any line edits - in particular, any
suggestions about keeping this bounded in time would be really helpful. Thanks.
From:
)
Sent: Friday, November 26, 2021 8:13 PM
To:
Subject: Re: Q&A
Yes
Sent from my iPhone
On Nov 26, 2021, at 16:47,
wrote:
If I send you the Q&A late tonight/early tomorrow morning, do you think you could review and send me any comments
you might have before she arrives on Saturday night?
Thanks so much for all your help.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
"
To:
Subject: Re: Epstein
Date: Thu, 27 Jun 2019 20:41:53 +0000
Importance: Normal
Good to hear that.
Sent from my iPhone
On Jun 27, 2019, at 4:28 PM,
wrote:
We obtained the list of victims in the side-letter to the NPA, and confirmed that our principal NY victim is not on it - it
appears that all the victims are Florida.
Public Corruption Unit
United States Attorney's Office for the
t.
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=== Page 1 ===
From:
To:
Subject: FW: Travel approval request
Date: Wed, 10 Jul 2019 02:10:32 +0000
Importance: Normal
Hi
It's still up in the air whether I'll be on this trip to Florida later this week, but could you please create a travel authorization
just in case? Thank you!
From:
Sent: Tuesday, July 09, 2019 19:38
To:
Subject: Travel approval request
Traveler,
Please have your legal asst. create a travel auth. in E2 for
to officially fund & approve today. Thanks
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_layouts/15/WopiFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%20Library/TravelStateTaxExemption.pdf&action-default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
for approval.
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
EFTA00015580

=== Page 2 ===
From:
Sent: Tuesday, July 09, 2019 2:09 PM
To:
is
Cc:
is
Subject: RE: travel approval request
Thanks!
From:
Sent: Tuesday, July 9, 2019 2:08 PM
To:
is
Cc:
Subject: RE: travel approval request
Approved for the travel and necessary conference room.
Thank you for correctly setting your priorities.
From:
Sent: Tuesday, July 09, 2019 2:00 PM
To:
is
Cc:
Subject: RE: travel approval request
Hi
In connection with the Epstein case (2018R01618), we would like to request permission to travel this week for victim
interviews in Palm Beach, Florida. Our agents will be there starting tomorrow, through Sunday, and our current plan is for
some combination of our team
(
,
and me) to be there from Thursday*** through Sunday. And also same as
last time, we'd like to ask permission to reserve a conference room at the hotel for those four days.
Thanks very much,
***we would never miss the BBQ.
From:
Sent: Wednesday, June 12, 2019 3:28 PM
To:
Cc:
is
Subject: RE: travel approval request
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
To:
Cc:
is
Subject: RE: travel approval request
EFTA00015581

=== Page 3 ===
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
,
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
>
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
> wrote:
EFTA00015582

=== Page 4 ===
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Meeting
Date: Mon, 06 Jan 2020 16:21:32 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
To:
Subject: News Brief
Date: Fri, 27 Aug 2021 21:00:39 +0000
Have a good weekend everyone...
Justice Dept. to Close Troubled Jail Where Jeffrey Epstein Died The 233 people being held at the
Metropolitan Correctional Center will be moved, at least temporarily, while officials address conditions there.
https://www.nytimes.com/2021/08/26/nyregion/MCC-epstein-jail-closed.html
Hatescape: An In-Depth Analysis of Extremism and Hate Speech on TikTok - Institute for Strategic
Dialogue (24 August 2021) TikTok is now one of the world's leading social media platforms, used by millions
daily to create videos that are stylish, eye-catching and technically impressive and that inspire others to join
in. The platform's videos give rise to countless viral trends across online platforms, with content spread
across other social media sites. But TikTok is also popular with those intent on using online spaces to
produce, post and promote hate and extremism. Academic research and news investigations have reported on
the problematic side of TikTok, but there is still a significant knowledge gap on how unique aspects of the
platform are used at scale to direct hatred at others. ISD set out to examine the state of hate on TikTok in two
ways. The first objective involved analysing how individuals or groups promote hateful ideologies and target
people on the platform based on numerous protected attributes such as ethnicity, religion, gender or others. The
second objective involved using the same framework but investigating how features on TikTok like
profiles, hashtags, share functions, video effects and music are used to spread hate.
Attorney General Merrick B. Garland Delivers Remarks At Justice Department Leadership Meeting With State
And Local Election Officials On Threats To Election Workers [DOJ] Multiple Field Offices
EFTA00015646

=== Page 2 ===
The right to vote is the foundation of our democracy, the right from which all other rights ultimately flow.
Protection of that right is a top priority of the Justice Department. Indeed, it was one of the principal
reasons for the Department's founding in 1870.
Today [Aug. 26], we must protect not only the right of eligible voters to vote. We must also protect those
who administer our voting systems from threats and intimidation. Only by protecting those who
administer the election process can we ensure that the right to vote, itself, is protected.
See press release for further details.
T-Mobile Hacker Who Stole Data On 50 Million Customers: 'Their Security Is Awful' [Wall Street Journal] SE
and NK
John Binns, a 21-year-old American who moved to Turkey a few years ago, told The Wall Street Journal he
was behind the [T-Mobile] security breach. Mr. Binns, who since 2017 has used several online aliases,
communicated with the Journal in Telegram messages from an account that discussed details of the hack
before they were widely known.
The breach is the third major customer data leak that T-Mobile has disclosed in the past two years. The
Bellevue, Wash., company is the second-largest U.S. mobile carrier with roughly 90 million cellphones
connecting to its networks. The Seattle office of the FBI is investigating the T-Mobile hack.
"John Binns" is positive in FBI holdings for captioned matter. Program Manager: Cyber
Capitol Police Officers Sue [President] Trump And Extremist Groups Over [2021] Capitol Riot [Courthouse
News] WFO and Multiple Field Offices
A group of seven U.S. Capitol Police officers sued [President] Trump and a slew ["nearly 20"] of far-right
extremist organizations and political organizers on Thursday [Aug. 26] over the Jan. 6 [2021] Capitol riot,
in the most comprehensive and expansive lawsuit filed regarding the riot thus far.
The officers claim Trump, the Proud Boys, the Oath Keepers, Trump ally Roger Stone and others conspired
to use violence to stop Congress from certifying President Joe Biden as the winner of the 2021
presidential election, and that [President] Trump worked with these organizations and political organizers
to promote the baseless claim that the election was stolen.
Robert F Kennedy Assassin [1968] Sirhan Seeks Parole; DA Won't Challenge Release [AP News] LA
Sirhan Sirhan faces his 16th parole hearing Friday [Aug. 26] for fatally shooting U.S. Sen. Robert F.
Kennedy in 1968, and for the first time no prosecutor will be there to argue he should be kept behind
bars.
The 77-year-old Sirhan has served 53 years for the first-degree murder of the New York senator and
brother of President John F. Kennedy. RFK was a Democratic presidential candidate when he was gunned
down at the Ambassador Hotel in Los Angeles moments after delivering a victory speech in the pivotal
[1968] California primary.
"Sirhan Sirhan" is positive in FBI holdings for captioned matter. Program Manager: CID
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"Documentary" Profiling White Nationalist Group Released On Blockchain Video Platform [SITE Intelligence]
Multiple Field Offices
A documentary-style propaganda film promoting one of the most high-profile far-right groups in the
United States was recently released via a far-right-friendly video-hosting platform.
Media2Rise published what is purportedly only the first part of "Sons of the Founders," a documentary
about the white nationalist activist group Patriot Front. The 12 minute, 43 second video was published
both to Odysee, a blockchain-based video hosting website favored by the far-right, and Media2Rise's
Telegram channel.
"Sons of the Founders" features footage from what Media2Rise describes as exclusive access to a Patriot
Front training camp at an undisclosed location. (Founder and leader Thomas Rousseau describes the
location as being on "the coast of the Atlantic, or as close as I've ever been.")
"Thomas Rosseau" is positive in FBI holdings for captioned matter. Program Manager: DTOU
Extremist groups 'actively recruiting' military and police, Canadian intelligence report warns
By Stewart Bell, Global News, Posted August 23, 2021 4:00 am, Updated August 23, 2021 9:32 am
https://globalnews.ca/news/8128463/extremist-groups-military-recruitment-report/
Far-right extremist groups are "actively recruiting" past and present members of the military and police, according to a
declassified Canadian intelligence report obtained by Global News. The report cited 17 examples in Canada, the U.S.,
U.K., Germany and New Zealand which "illustrate the intersections and relationships between ideologically motivated
violent extremism and uniformed personnel." Six of the cases involved members of the Canadian military or reserves It
said the groups included the Proud Boys, Oath Keepers and Boogaloo Movement, as well as the Three Percenters - a so-
called patriot group that took part in the Jan. 6 assault at the U.S. Capitol.
Chicago CBP Seizes Counterfeit DEA Badges, Again!
US Customs and Border Protection Media Release, Release Date: August 24, 2021
https://www.cbp.gov/newsroom/local-media-release/chicago-cbp-seizes-counterfeit-dea-badges-again
CHICAGO- Just last weekend, U.S. Customs and Border Protections (CBP) officers at the Chicago International Mail
Branch (IMF) seized eight Drug Enforcement Administration (DEA) badges and one FBI badge. Over the last two days,
August 22 and 23, CBP officers found more counterfeit badges; this time officers intercepted 26 counterfeit DEA badges.
CBP inspected 25 parcels to determine the admissibility of the contents. Officers seized a total of 26 badges all destined
for locations across the U.S to include: Washington, lowa, Kentucky, Florida, California, New Jersey, New York,
Pennsylvania, Michigan, Virginia, Indiana, Ohio, Texas, and Illinois. These shipments were all arriving from China and were
sent by the same shipper from the previous week
Treasury Targets Corruption Networks in Paraguay
US Department of the Treasury Press Release, August 24, 2021
https://home.treasury.gov/news/press-releases/jy0332
IPT NOTE: See item #32 below for analysis.
WASHINGTON - Today, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned three
Paraguayan individuals, Kassem Mohamad Hijazi, Khalil Ahmad Hijazi, and Liz Paola Doldan Gonzalez, for their roles in
corruption in Paraguay, as well as five associated entities connected with their corruption schemes. These individuals and
entities are designated pursuant to Executive Order (E.O.) 13818, which builds upon and implements the Global Magnitsky
Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world.
Corruption degrades the rule of law, weakens economies and stifles economic growth, undermines democratic institutions,
perpetuates conflict, deprives innocent civilians of fundamental human rights, and is intrinsically linked to money laundering
and lack of financial transparency. Today's action further demonstrates the U.S. government's ongoing effort to impose
tangible and significant consequences on corrupt actors in order to protect the U.S. financial system from abuse. Click
here to view more information on today's designation. https://home.treasury.gov/policy-issues/financial-sanctions/recent-
actions/20210824
Coordinated Law Enforcement and Treasury Action Against Money Launderers in the Tri-Border Area
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Emanuele Ottolenghi, Senior Fellow, Foundation for Defense of Democracies (FDD), August 25, 2021 I Policy Brief
https://www.fdd.org/analysis/2021/08/25/money-launderers-tri-border-area/
IPT NOTE: See related item #14 above.
Emanuele Ottolenghi is a senior fellow at the Foundation for Defense of Democracies (FDD), where he also contributes to
FDD's Center on Economic and Financial Power (CEFP). FDD is a Washington, DC-based, nonpartisan research institute
focusing on national security and foreign policy.
Groundbreaking extradition lands ELN members in Texas for narco-terrorism and international cocaine
distribution
Possible $5 million reward for alleged leader
U.S. Attorney's Office, Southern District of Texas, Thursday, August 19, 2021
https://www.justice.gov/usao-sdtx/pr/groundbreaking-extradtion-lands-eln-members-texas-narco-terrorism-and-
international
HOUSTON - Two alleged members of one of the most serious transnational criminal organizations will make their initial
appearances in U.S. federal court on charges of narco-terrorism and distributing kilogram quantities of cocaine from
Colombia. This is the first time believed members of the National Liberation Army (Ejército de Liberación Nacional aka
ELN) have been extradited to the United States in their nearly 60-year history to face both narco-terrorism and drug
trafficking charges. ELN is a Colombian guerrilla group officially designated as a foreign terrorist organization Oct. 8, 1997.
It continues to operate as one of the largest narco-terrorism organizations in the world.
Afghanistan Live Updates: Toll in Kabul Airport Bombing Rises to 170 After a blast that killed 13 U.S. troops, evacuation
flights have resumed. With four days remaining until an Aug. 31 deadline for the U.S. withdrawal, the window for airlifts is
narrowing. (as of 11:33am)
Read the latest
U.S. officials provided Taliban with names of Americans, Afghan allies to evacuate
"Basically, they just put all those Afghans on a kill list," said one defense official.
By Lara Seligman, Alexander Ward, & Andrew Desiderio, Politico.com Exclusive, 08/26/2021 03:28 PM EDT
htp://ww.politico.com/news/2021/08/26/us-offcials-provided-taliban-with-names-of-americans-afghan-alies-to-evacuate-
506957
U.S. officials in Kabul gave the Taliban a list of names of American citizens, green card holders and Afghan allies to grant
entry into the militant-controlled outer perimeter of the city's airport, a choice that's prompted outrage behind the scenes
from lawmakers and military officials. The move, detailed to POLITICO by three U.S. and congressional officials, was
designed to expedite the evacuation of tens of thousands of people from Afghanistan as chaos erupted in Afghanistan's
capital city last week after the Taliban seized control of the country. It also came as the Biden administration has been
relying on the Taliban for security outside the airport. But the decision to provide specific names to the Taliban, which has
a history of brutally murdering Afghans who collaborated with the U.S. and other coalition forces during the conflict, has
angered lawmakers and military officials.
ISKP Claims Attack Near Hamid Karzai International Airport As Suicide Bombing [SITE Intelligence]
The group's 'Amaq News Agency issued a report on the incident on August 26, 2021, and provided a
photo of the bomber, "Abdul Rahman al-Logari".
According to the message, the Khorasan Province (ISKP) fighter reached a distance of "no more than five
meters from the American forces," and detonated his explosive belt, killing 60 and wounding over 100
others. IS "military sources" said more than 20 American soldiers were killed and wounded in the attack.
See also SITE: IS-Aligned Unit Quickly Crafts Propaganda Poster From ISKP Claim For Attack Near Hamid
Karzai International Airport
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Islamic State pours scorn on Taliban victory in Afghanistan while experts warn of 'new phase of jihad'
David Rose, Beirut, The Times (London), Friday August 20 2021, 12.00pm BST,
https://www.thetines.co.uk/article/islamic-state-pours-scorn-on-taliban-victory-in-afghanistan-while-experts-warm-of-new-
phase-of-jihad-3v72qg3dq
Islamic State has poured scorn on the Taliban's victory in Afghanistan, claiming that its Islamist rival had merely been
handed the country by the withdrawal of American troops. In its first comment since the Taliban's takeover in Kabul, the
terrorist group declared that the Afghan movement had not fought a true "jihad" - or holy war - and expressed doubt that
it could implement true sharia law in Afghanistan. It also mocked "the new Taliban" as a tool "in the guise of Islam", which
would be used by the US to mislead Muslims and to fight Islamic State's own presence in the region. The comments came
in an editorial in the group's al-Naba newspaper, which is disseminated online via encrypted messaging apps, despite
efforts to suppress it, and is considered a mouthpiece for the group's leaders. "It is a victory for peace, not for Islam; [a
victory] for negotiations, not jihad," the editorial published yesterday said, referring to the Taliban's takeover. Analysts said
that Isis militants were "jealous" of their ideological rivals' success, but also noted the group's warning that it could stage a
"new phase of jihad" in response, including in Afghanistan
What We Know About The Kabul Airport Attack That Killed US Troops [ABC News]
An explosion that killed at least 13 U.S. service members in Afghanistan Thursday [Aug. 26] was part of a
"complex" attack near the Kabul airport, the Pentagon said.
Two ISIS suicide bombers detonated in the vicinity of both the Kabul airport's Abbey Gate and the
adjacent Baron Hotel, according to Gen. Kenneth McKenzie, the commander of U.S. Central Command.
The U.S. service members killed included 10 Marines, one Army, one to be determined and one Navy
hospital corpsman, or medic. A 13th service member injured in the attack later died.
For associated photo and video attack coverage see Daily Mail - UK: 'We Will Make You Pay': Emotional
[President] Biden Vows To 'Hunt Down' ISIS-K For Double Suicide Bomb Attack That Killed 13 US Troops
And 90 Afghans. Takes Responsibility For Carnage But Stands By Troop Withdrawal
After Decades Of War, ISIS And Al Qaeda Can Still Wreak Havoc [New York Times]
The twin suicide bombings near the Kabul airport on Thursday [Aug. 26] underscored the devastating
power these groups still have to inflict mass casualties in spite of the American effort.
And they raised haunting questions about whether the Taliban can live up to the central promise they
made when the Trump administration agreed in early 2020 to withdraw American forces from the
country - that Afghanistan would no longer be a staging ground for attacks against the United States and
its allies.
The Taliban's lightning takeover of the country hardly assures that all militants in Afghanistan are under
their control. To the contrary, the Islamic State affiliate in Afghanistan - known as Islamic State Khorasan
or ISIS-K - is a bitter, albeit much smaller, rival that has carried out dozens of attacks in Afghanistan this
year [2021] against civilians, officials and the Taliban themselves.
The Taliban Are Far Closer to the Islamic State Than They Claim - Foreign Policy (26 August 2021)
In an early sign of Afghanistan's dystopian future as well as a reminder of its dark past, a coordinated suicide
attack hit several locations in Kabul, including a hotel and the airport. Dozens of people were killed and
hundreds injured, including Afghan civilians attempting to leave the country and the U.S. soldiers overseeing
the evacuation. Islamic State-Khorasan has taken responsibility, but the Taliban faction partially in control of
security in Kabul over the past several days, the Haqqani network, must also be scrutinized. Ultimately, the
attack strategically benefits the Haqqani as it will likely speed up foreign departures and prevent the prospect of
further evacuations. There have been repeated warnings of a potential airport attack over the last week. When
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it came, it was not spontaneous or random but a well-planned assault, using multiple bombs and targets
calculated to achieve several objectives. The first and most obvious goal was to kill fleeing Afghans and
discourage others from attempting to leave via the airport-or to close the airport itself. But another goal was
the death of coalition troops, thus using the specter of terror to ensure the West stuck to the agreed on Aug.
31 deadline to leave the country. The timing of the attack, on the cusp of the 20th anniversary of the 9/11
attacks, sends out a powerful signal to other jihadists.
In Taliban-Ruled Afghanistan, AI Qaeda-Linked Haqqani Network Rises to Power
Haqqani network's new prominence undermines Taliban's claims of severing terrorist ties
By Sune Engel Rasmussen and Nancy A. Youssef, Wall Street Journal, Aug. 26, 2021 11:00 am ET
https://www.wsj.com/articles/in-taliban-ruled-afghanistan-al-gaeda-linked-haggani-network-rises-to-power-11629990056?
st=501g0ng6ghosyy9&reflink=desktopwebshare_permalink
After taking control of Afghanistan, the Taliban has pledged to be a responsible member of the international community that
doesn't pose a threat to any country's security. However, the Islamist movement's victory in Afghanistan has elevated its
most radical and violent branch, the Haqqani network. Having perpetrated some of the deadliest attacks of the 20-year war,
the network-unlike the broader Taliban-has been designated as a terrorist organization by the U.S. since 2012. Closely
linked to al Qaeda, the network also has for decades been involved in the hostage-taking of Westerners, and currently
holds at least one American citizen captive, according to U.S. officials. "I do not believe that anyone in the West fully
understands the reach of the Haqqani network," said retired Lt. Gen. Michael K. Nagata, a former director of strategy for
the National Counterterrorism Center. "It is the single most impressive nonstate militant group I have ever seen, with the
exception of ISIS in the first two years of the caliphate.'
Who are Isis-K, the new threat on Afghan horizon?
Catherine Philp, Diplomatic Correspondent, The Times (London), August 25 2021, 5.00pm BST
https://www.thetimes.co.uk/article/who-are-isis-k-the-new-threat-on-afghan-horizon-vnxlnwnxk
Military planners are warning that the chaos in Afghanistan could give rise to a separate and more extreme threat than
even the Taliban, as the regional arm of Islamic State seeks to strengthen its position. Isis-K, or the Islamic State of
Khorasan, is an affiliate of the group that overran large parts of Syria and Iraq to establish a so-called "caliphate". Isis-K,
established in eastern Afghanistan in 2015, is a sworn enemy of the Taliban and the two groups have clashed repeatedly. It
was initially drawn largely from fighters of the Pakistani Taliban, not the Afghan group, but has raided the Afghan Taliban's
ranks too. Khorasan is a traditional name for the Central Asian and South Asian area that Afghanistan is part of, similar to
the name al-Sham that the group used to refer to the Levant. Unlike the Afghan Taliban, whose focus remains on
Afghanistan, Isis-K has repeatedly articulated its desire to attack the United Nations and western powers. While its strength
is focused in the provinces bordering Pakistan, the source of present concern about the group is its ability to strike the
capital, Kabul, as it has before with suicide bombings
Also, NY Post: https://nypost.com/2021/08/26/who-are-isis-k-what-to-know-about-the-afghan-terrorist-group/?
utm_campaign=nypdaily&utm_sourcessaithru&utm_medium=emal&utm_content=20210827&utm_term=NYP&20-
%20Morning%20Report
Who are Isis-K, the Islamic State insurgents suspected of plotting attacks in Kabul airport?
The splinter cell does not have a friendly relationship with the Taliban in Afghanistan
By James Rothwell, The Daily Telegraph (London), 25 August 2021 1:18pm
https://www.telegraph.co.uk/world-news/2021/08/25/isis-k-islamic-state-insurgents-suspected-ploting-attacks-kabul/
President Joe Biden has cited a potential terror attack by the Isis-K group as grounds for speeding up the Afghanistan
evacuation efforts at Kabul airport. Here we look at how Isis-K came to exist and why it poses such a threat to US forces
in Afghanistan
CIA, U.S. Troops Conduct Missions Outside Kabul Airport to Extract Americans, Afghan Allies
Risky operations include helicopter lifts, ground troops as evacuation window closes
By Gordon Lubold, Warren P. Strobel and Jessica Donati, Wall Street Journal, Updated Aug. 25, 2021 5:04 pm ET, Print
Aug 26, 2021
https://www.wsj.com/articles/cia-u-s-troops-conduct-missions-outside-kabul-airport-to-extract-americans-alies-
11629915605?st=rxppa0fo6cemsgr&reflink=desktopwebshare_permalink
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WASHINGTON-The Central Intelligence Agency and the U.S. military are conducting extraction operations to evacuate
Americans using helicopters and ground troops as the window begins to close for rescuing all people at risk in Afghanistan.
The CIA has launched clandestine operations to rescue Americans in and outside Kabul in recent days, according to U.S.
and other officials. The missions are using American military helicopters but under the control of the CIA, a typical
arrangement in such operations. A congressional source knowledgeable about the evacuation effort said U.S. troops had
gone into Kabul on joint missions with other foreign allies, including Britain and France, to designated locations where they
had picked up citizens from all those nations, U.S. green-card holders, and Afghans who hold special visas for helping the
U.S. military.
British Embassy Left Details Of Afghan Staff For Taliban To Find [Times Of London - UK]
[UK] Foreign Office staff left documents with the contact details of Afghans working for them as well as
the CVs of locals applying for jobs scattered on the ground at the British embassy compound in Kabul that
has been seized by the Taliban.
The papers identifying seven Afghans were found by The Times on Tuesday [Aug. 25] as Taliban fighters
patrolled the embassy.
Phone calls to the numbers on the documents revealed that some Afghan employees and their families
remained stranded on the wrong side of the airport perimeter wall days after their details were left in the
dirt in the haste of the embassy's evacuation on August 15.
Five Daesh, Al-Qaeda Suspects Arrested In Istanbul [Turkey] [Yeni Safak - TUR]
Five suspects were arrested in Turkey on Thursday [Aug. 26] during operations against the Daesh and al-
Qaeda terror groups. The suspects were seized in simultaneous raids at nine different places in seven
districts of Istanbul.
From Middle East Monitor - UK: As many as 10 people suspected of having links to the Daesh terror
group were arrested in Istanbul province, police said on Sunday [Aug. 22]. 10 Daesh Suspects Arrested In
Istanbul
Nigerian Government Says "Safe to Assume" Boko Haram Leader is Dead
On August 23, Nigeria's government said that it no longer has
any doubts that Abubakar Shekau, the leader of Boko Haram, is
dead.
Reports of Shekau's death first emerged three months
ago following a confrontation between Boko Haram and
its rival, Islamic State West Africa Province (ISWAP),
in the Sambisa Forest.
Nigerian officials initially expressed skepticism about
the reports.
On August 23, Information Minister Lai Mohammed
said in an interview that "our position is that he has been
reported dead and he is dead."
Mohammed cited the "instability and the struggle for
succession," thousands of Boko Haram adherents
surrendering, and "reports from the camp of Boko
Haram itself" as evidence.
A U.S. military official agreed, stating, "We think he
was probably killed."
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https://www.voanews.com/africa/nigeria-says-safe-assume-boko-haram-leader-dead
MTA Daily:
Significant Dates in History
August 27, 1979
Northwest coast of Ireland
Mountbatten Killed by IRA
Brief Description: On August 27, 1979, Lord Louis Mountbatten is killed when Irish Republican Army (IRA) terrorists
detonate a 50-pound bomb hidden on his fishing vessel Shadow V. Mountbatten, a war hero, elder statesman, and
second cousin of Queen Elizabeth II, was spending the day with his family in Donegal Bay off Ireland's northwest
coast when the bomb exploded. Three others were killed in the attack, including Mountbatten's 14-year-old
grandson, Nicholas. Later that day, an IRA bombing attack on land killed 18 British paratroopers in County Down,
Northern Ireland.
The assassination of Mountbatten was the first blow struck against the British royal family by the IRA during its long
terrorist campaign to drive the British out of Northern Ireland and unite it with the Republic of Ireland to the south.
The attack hardened the hearts of many Brits against the IRA and convinced Margaret Thatcher's government to take
a hard-line stance against the terrorist organization.
The IRA immediately claimed responsibility for the attack, saying it detonated the bomb by remote control from the
coast. It also took responsibility for the same-day bombing attack against British troops in County Down, which
claimed 18 lives.
IRA member Thomas McMahon was later arrested and convicted of preparing and planting the bomb that destroyed
Mountbatten's boat. A near-legend in the IRA, he was a leader of the IRA's notorious South Armagh Brigade, which
killed more than 100 British soldiers. He was one of the first IRA members to be sent to Libya to train with
detonators and timing devices and was an expert in explosives. Authorities believe the Mountbatten assassination
was the work of many people, but McMahon was the only individual convicted. Sentenced to life in prison, he was
released in 1998 along with other IRA and Unionist terrorists under a controversial provision of the Good Friday
Agreement, Northern Ireland's peace deal. McMahon claimed he had turned his back on the IRA and was becoming
a carpenter.
Regards,
Senior Intelligence Specialist
U.S. Attorney's Office - SDNY
Terrorism & International Narcotics Unit
One St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: forfeiture question
Date: Fri, 28 Jun 2019 18:23:53 +0000
Importance: Normal
Yes, that's perfect. Will come down then. Thanks
From:
Sent: Friday, June 28, 2019 2:21 PM
To:
Cc:
Subject: Re: forfeiture question
I'm going to be back and free by 3 if that's better.
Sent from my iPhone
On Jun 28, 2019, at 1:41 PM,
wrote:
I have a date with Judge Sullivan at 4, so I will stay for as long as I can.
From:
Sent: Friday, June 28, 2019 1:32 PM
To:
Cc:
Subject: RE: forfeiture question
Thanks!
From:
Sent: Friday, June 28, 2019 1:30 PM
To:
Cc:
Subject: Re: forfeiture question
3:30 works for me.
Sent from my iPhone
On Jun 28, 2019, at 12:49 PM,
wrote:
Hi
Are you free for a few minutes this afternoon to discuss a forfeiture question relating to a property we are hoping to
forfeit in the Jeffrey Epstein case? Ted and I are available from 1 to 2, or from 2:30 to 4, if there is a window in that
timeframe that works for either of you.
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Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Jeffrey EPSTEIN
Date: Thu, 25 Jul 2019 02:41:23 +0000
Received, thanks for passing this on. Do you have any additional information or reports?
On Jul 24, 2019, at 9:35 PM,
wrote:
All,
Please be advised that we received he following report from the Bureau of Prisons MCC New York at 2115 hours on this
date:
Associate Warden (AW)
at MCC New York advised that Jeffrey EPSTEIN was found in his cell this
morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was
assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he
currently remains. Additionally, AW
advised that EPSTEIN's cell mate reported threated to kill him. No
further information was provided.
The above incident is currently under investigation with the BOP.
S
Supervisory Deputy United States Marshal
Southern District of New York
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From:
To:
(USANYS)"
Subject: Automatic reply: Why the Feds Cannot Forfeit Jeffrey Epstein's Mansion
Date: Tue, 17 Sep 2019 18:18:27 +0000
I will be out of the office on work travel until September 20th. I will be checking email intermittently, but if you
need urgent assistance before then, please contact
at
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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
Date: Sat, 11 Jul 2020 21:17:01 +0000
We just were contacted by defense counsel, who said they didn't have a call with their client this morning - I think they
expected that the morning calls up until her arraignment on Tuesday would include the weekend. Is it possible to
reinstitute the call for tomorrow at 10:00, as well as on Monday? Thanks very much, and sorry for the late notice - we
just heard from them a moment ago.
thanks,
From:
Sent: Friday, July 10, 2020 10:34
To:
Cc:
in
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Great - thank you again! (I told defense counsel that I would ask, but also just to give it a few minutes
.)
Sent from my iPhone
On Jul 10, 2020, at 10:30,
wrote:
I've been informed she is on the phone
"
)"
7/10/2020 10:26 AM
Defense counsel for Maxwell communicated to us a few minutes ago that they haven't gotten a call yet this morning. Do
you know if that has gone through in the past five or ten minutes? They are looking to speak with her before her
interview with pretrial this afternoon.
I'm reachable at
if it's useful to chat in real time.
thanks,
On Jul 7, 2020, at 19:50,
wrote:
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=== Page 2 ===
You're welcome. We will do our best to provide a call at 10:00 AM every day this week to Mr. Everdell at the
number he has previously provided. We will also provide a call on Monday 7/13/20.
The EDNY and SDNY created a joint protocol whereby counsel may request legal calls to be placed in the
afternoon at the MDC. Requests should be sent to
Truly urgent requests can be sent to me, but unless there is a last minute, imminent court deadline, counsel
really should send the requests to the federal defenders, as outlined in the protocol. We want to ensure inmates
get equitable access. If they anticipate needing several calls in a week, they should make requests in advance
and note whether and when calls would be preferred. Generally, calls are for 30 minutes in duration. If a
longer call is desired, that should be explained as well.
If you need anything else, please let me know.
Thank you,
)"
7/7/2020 5:00 PM
Thank you so much,
A 10am standing legal call every day before the arraignment on Tuesday 7/14 would be perfect if that's something you
would be able to accommodate. Defense counsel will be available at that time, and they are very grateful for the
time.
We have also conveyed to defense counsel that they will need to follow the same protocols as other inmates' counsel
following the arraignment. Thank you for letting us know about the lack of requests from defense counsel thus far.
There appears to be some confusion on their end about how to submit requests to schedule legal calls. Would you be
able to please share with us the procedure that they should follow, so that we can make sure they understand what
steps to take going forward?
Thank you again for all of your help-we really appreciate it.
Best,
From:
Sent: Tuesday, July 7, 2020 4:23 PM
To:
Cc:
is
)
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
You're welcome.
Would 10 am work as a standing legal call through the end of this week (and Monday, if you think that's a good idea), in
advance of the arraignment on Tuesday? However, after this, defense counsel should be required to follow the same
protocols as all other inmates' counsel with respect to requesting legal calls.
I also just want to make clear that defense counsel sent no requests yesterday that I am aware of, and we were able to
facilitate a call yesterday evening following a request from your office, and today, I received one request, about mid-day,
that we were again able to accommodate. So, I do not think it is fair at all to categorize this as defense counsel having
difficulty scheduling legal calls.
Thank you,
^^^
)"
7/7/2020 2:37 PM >>>
Thanks,
This is about the legal call today. In addition, because defense counsel his having difficulty scheduling
legal calls, it would be helpful if MDC could schedule standing calls for the rest of this week to address this issue.
Thanks very much.
From:
Sent: Tuesday, July 7, 2020 2:36 PM
To:
EFTA00015952

=== Page 3 ===
Cc:
is
)
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Hi
I just saw this now. Is this about the legal call issue or something separate? If it's about the legal call, I am working on it.
Thanks,
=
)"
> 7/7/2020 1:27 PM>>>
Hi
Thanks for your help with this. Are you available now for a call? We are having a time sensitive issue with this.
Thanks,
Sent from my iPhone
On Jul 6, 2020, at 7:59 PM,
<
> wrote:
Hi
For future reference, there is a protocol in place for defense counsel to reques legal calls. If counsel is unaware of it, I
can provide the details.
However, I understand that she just came into custody today and there is a more urgent deadline. If you can please
provide the name and phone number of counsel, I will do my best.
Thanks,
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)" <
>
Date: 7/6/20 7:48 PM (GMT-05:00)
To:
<
>
Cc:
>,
>
Subject: Ghislaine Maxwell (USMS No. 02879-509)
>>>
)" 07/06/2020 19:48 >>>
Hi
Hope you're doing well. This evening, Judge Nathan directed the parties in the US V. Ghislaine Maxwell case to file a
letter by 9pm today. Defense counsel need to speak with Ms. Maxwell this evening about the letter, but they have
not been able to reach her. Would it be possible to allow Ms. Maxwell to make a legal call to her lawyers this
evening, please?
Thank you very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015953


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=== Page 1 ===
Mod AO 442 (09/13) Arrest Warrant AUSA Name & Telno:
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
V.
)
)
Case No.
)
)
)
Ghislaine Maxwell
)
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested)
Ghislaine Maxwell
,
who is accused of an offense or violation based on the following document filed with the court:
Indictment
Superseding Indictment
Information
Superseding Information
Complaint
Probation Violation Petition
Supervised Release Violation Petition
Violation Notice
Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (conspiracy to entice minors)
Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
Title 18, United States Code, Section 371 (conspiracy to transport minors)
Title 18, United States Code, Sections 2423(a) and 2 (transportation of a minor)
Title 18, United States Code, Section 1623 (perjury)
Date:
06/29/2019
Issuing officer's signature
City and state:
White Plains, NY
Hon. Lisa Margaret Smith, U.S. Magistrate Judge
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on (date)
at (city and state)
Date:
Arresting officer's signature
Printed name and title
EFTA00016391


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=== Page 1 ===
From:
(USANYS)"
To: "
Cc:
)"
Subject: Epstein report
Date: Thu, 12 Dec 2019 13:05:18 +0000
We have considered your request and are willing to let you take the document you reviewed yesterday to your office for
review today on the following conditions:
1 - The report must be returned to our office by 5 pm tonight.
2 - The document will be treated as Attorney Eyes Only.
3 - The document will not be reproduced in any way (e.g. photocopying).
Assuming you are ok with these conditions, please let us know what time you'd like to pick it up. I'll be around all
morning after 9:30 so let me know and I'll have it ready for you.
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
EFTA00016895


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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Epstein
Date: Thu, 11 Jul 2019 13:52:34 +0000
Importance: Normal
Correct
Sent from my iPhone
On Jul 11, 2019, at 09:47,
wrote:
Nothing on today, right?
Sent from my iPhone
Begin forwarded message:
From: Juliet Papa
Date: July 11, 2019 at 9:38:53 AM EDT
To:
Subject: Re: Epstein
Thank you for confirming. I told my desk that and they were insisting he had a court appearance. Either they
are reading something incorrectly or wires have it wrong.
Juliet Papa
Reporter
1010 WINS Radio
1010WINS.com
Entercom
Twitter:
Sent from my iPhone
On Jul 11, 2019, at 8:45 AM,
wrote:
Nope. Monday at 10:00 am, Judge Berman. The defense brief is due today and our response is due
tomorrow.
Sent from my iPhone
On Jul 11, 2019, at 8:12 AM, Juliet Papa
wrote:
EFTA00015634

=== Page 2 ===
Hi
-does he have a court appearance today? Thanks-
Juliet Papa
Reporter
1010 WINS Radio
1010WINS.com
Entercom
Twitter:
Sent from my iPhone
EFTA00015635


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
To:
Ce:
Subject: SDNY NEWS CLIPS, OCTOBER 5, 2020
Date: Mon, 05 Oct 2020 14:39:21 +0000
Inline-Images: image0.jpeg
OF
SDNY PRESS CLIPPINGS
JUSTITIA
MAXWELL (EPSTEIN):
NEWSWEEK:
MATTERS OF INTEREST
WSJ: ts://www.wsi.com/articles/nypd-prepares-for-potential-unrest-after-presidential-election-1160190223123st-ryyp4ciesnhisy&reflink-article_copyL/RL_share
WASHINGTON TIMES: https://www.washingtontimes.com/news/2020/oct/4/how-treasury-dept-tracked-overseas-cash-pocketed-b
BULWARK: https://thebulywark.com/the-transformation-of-mike-pompeo/
CNN: https://www.cnn.com/2020/10/04/politics/william-bar-quarantine-coronavins/index.htm
DAILY BEAST: https://www.thedailybeast.com/john-w-dick-leak-exposes-jerseys-inaction-on-fraud-scanda
FORBES: https://www.forbes.com/sites/andreatinianow/2020/10/05/crypto-fraudster-pleads-guilty-to-fraud
NBC: https://www.nbcnews.com/feature/nbc-out/sexual-gender-minorities-much-likelier-be-crime-victims-n1242100
EFTA00015193


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 CR. 330 (AJN) - Government Opposition to Defense Motions
Date: Tue, 23 Mar 2021 03:12:41 +0000
Attachments: 2021-03-22_GM_letter_re_pre-trial_opposition_redactions_(final).pdf;
2021.02.26_Government_Omnibus_Opposition_to_Maxwell_Defense_Motions_FINAL_(Pr
posed_Redactions_Per_Order_and_Defense_Requested_Redaction).pdf
Exhibit_11_(Proposed_Redactions_Per_Order).pdf
Good evening,
Attached please find the Government's letter relating to redactions filed on ECF this evening, as well as the Government's
proposed redactions to its omnibus memorandum of law and the proposed redactions to Exhibit 11.
Respectfully submitted,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00016218


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=== Page 1 ===
From:
Subject: Travel Authorization 10982121 approved by
, now awaiting further
approval
Date: Fri, 24 Jan 2020 23:54:20 +0000
Importance: Normal
Dear
Travel authorization 10982121 has been approved by
, now awaiting further approval.
Trip ID: 10982121
Traveler name:
Purpose: R20NYS13341 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00017039


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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
name unavailable
Date: Fri, 16 Aug 2019 19:26:06 +0000
Attachments:
.wav
Time: Aug 16, 2019 3:26:06 PM
Click attachment to listen to Voice Message
EFTA00015699


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c0:
=== Page 1 ===
From:
To:
Subject: RE: Can you
Date: Mon, 15 Jul 2019 23:16:40 +0000
Importance: Normal
Yeah we're one step ahead -- the Marius Fortelni who lives in Southampton says on his website that he lived for a
time in Saudi Arabia, so given his nationality, the fact that the "residence" on the passport is Saudi Arabia, and
the fact that the age roughly appears to match up, we asked the agents to try to confirm the DOB but also to just
reach out to Mr. Fortelni and see if he has any knowledge of why a passport from his country, with his name and
former residence country, might be in Jeffrey Epstein's safe and with Jeffrey Epstein's face on it.
Original Message
From:
Sent: Monday, July 15, 2019 19:04
To:
Subject: Can you
Have an agent run the real Marius's DOB and compare to passport?
Sent from my iPhone
EFTA00014469


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=== Page 1 ===
From:
)"
To: Robert Glassman
Cc:
(USANYS)"
)"
Subject: Rule 412
Date: Fri, 29 Oct 2021 19:24:32 +0000
Attachments: Def_412_Mot._for_Glassman_Redacted.pdf
Robert,
As we discussed this morning, I'm attaching a copy of the Rule 412 motion, which was filed under seal. Our response will
be filed under seal on Monday. If the Court holds a hearing on the motion, it will be in camera on Friday, November 5,
2021.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00016264


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c7: images
c0:
=== Page 1 ===
From:
=
To:
=
:
<IMCEAEX-
_o=USA_ou=Exchange
=
Subject: Accepted: Epstein Press Meeting
Date: Fri, 28 Jun 2019 16:30:18 +0000
Importance: Normal
Attachments: unnamed
EFTA00014296


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c3: VOL00008
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c0:
=== Page 1 ===
From:
(CID) (FBI)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE:
Date: Thu, 07 May 2020 22:23:30 +0000
Ok, I will shoot you am email tomorrow with my desk number.
On May 7, 2020 18:22,
(USANYS)"
wrote:
That works for us. Let us know were/how best to reach you. Thanks
From:
(CID) (FBI)
Sent: Thursday, May 7, 2020 5:12 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE:
How about Monday 11am?
-
On May 7, 2020 17:10,
(USANYS)"
wrote:
Great. We're still working remotely, but perhaps we could set up a call for early next week? Would Monday or Tuesday
work for you?
From:
(CID) (FBI)
Sent: Thursday, May 7, 2020 5:09 PM
To:
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS)
Subject: RE:
,
Let me know what works for you and
,
I am back from DC and am available to meet anytime.
On May 7, 2020 17:06,
(USANYS)"
wrote:
Thanks very much,
And thanks for the virtual introduction.
welcome and very much look forward to working
with you. Once you're settled,
and I would love to set up a time to talk through this and some of the other cases
we have going with your squads.
And thanks very much for everything over the past few months,
Really appreciate it. I have no doubt we will
continue to talk regularly about MCC and our other cases together.
Best,
EFTA00016605

=== Page 2 ===
From:
(NY) (FBI)
Sent: Thursday, May 7, 2020 10:53 AM
To:
(USANYS)
Cc:
(CID) (FBI)
>;
(USANYS)
Subject:
Thank you for the call and the update on the Epstein investigation with regard to charging Ghislaine Maxwell.
As I mentioned,
(copied) has been chosen as the permanent ASAC for the NYO's Violent Crime/Gang Branch of
the Criminal Division.
will be coordinating with you,
and the rest of the team as we move forward.
To rehash some of the points regarding Maxwell to get
up to speed with the latest:
SDNY is close to a final decision on charging Maxwell regarding her complicity in Epstein's sex trafficking
FBI believes (as of January) that Maxwell is still living with a friend in the Boston suburb of Manchester by the Sea
Confirmed by historical pen register with cell site location and subpoenas to Amazon for delivery location
Since traditional surveillance, including a pole camera, are not suitable due to the secluded location, and in order to get
more recent information, you propose getting a renewed pen register and Amazon subpoena. Additionally, you and the
team may seek to get a mail cover.
It was a pleasure working with you,
and the team for the last several months.
Good luck moving forward with the case.
Best regards,
Supervisory Special Agent
FBI New York
EFTA00016606


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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
- WIRELESS CALLER
Date: Sat, 27 Jul 2019 00:56:52 +0000
Attachments:
wav
Time: Jul 26, 2019 8:56:52 PM
Click attachment to listen to Voice Message
EFTA00015710


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c0:
=== Page 1 ===
Event: Epstein/call in from
Start Date: 2008-06-13 14:00:00 +0000
End Date: 2008-06-13 14:30:00 +0000
Organizer:
Location:
ofc.
Class: X-PERSONAL
Date Created: 2008-06-11 15:27:49 +0000
Date Modified: 2022-10-02 08:11:24 +0000
Priority: 5
DTSTAMP: 2008-06-11 15:27:38 +0000
Attendee:
When: Friday, June 13, 2008 10:00 AM-10:30 AM (GMT-05:00) Eastern Time (US & Canada).
Where:
ofc.
you can participate by phone. Let me know best number, Thanks,
Original Message
From:
To:
Cc:
Sent: Wed Jun 11 10:29:23 2008
Subject: RE: Epstein
Spoke with
Everyone is good for 10:00 this Friday morning.
will be calling
office
From:
Sent: Wednesday, June 11, 2008 10:21 AM
To:
Cc:
Subject: RE: Epstein
EFTA00014181

=== Page 2 ===
I'm available anytime
From:
Sent: Wednesday, June 11, 2008 10:09 AM
To:
Cc:
Subject: RE: Epstein
Absolutely, I'm available from 10 to 11 and after 11 have a conflict.
From:
Sent: Wednesday, June 11, 2008 10:02 AM
To:
Cc:
Subject: Epstein
Would you guys be available Friday morning by telephone to discuss?
EFTA00014182


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c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
,
)"
Subject: Emailing:
20200702094828881_DRAFT.pdf
Date: Thu, 02 Jul 2020 13:48:57 +0000
Attachments:
20200702094828881_DRAFT.pdf
EFTA00017733


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: US V. Tartaglione, 16-cr-832 - Unsealing of Records
Date: Tue, 10 Sep 2019 20:56:29 +0000
Attachments: NYTLEGAL-_64879-v2-Tartaglione_Access_Letter.pdf
See attached. The NY Times has joined in the request to unseal the letters.
Assistant United States Attorney
From: Sumar, Al-Amyn
Sent: Tuesday, September 10, 2019 4:46 PM
To:
Cc: David McCraw
Subject: US V. Tartaglione, 16-cr-832 - Unsealing of Records
All,
Attached is a letter on behalf of the New York Times Company and reporter Ben Weiser regarding the above-
referenced case, which was sent to the Court today by fax.
Regards,
--
Al-Amyn Sumar
Legal Department
The New York Times Company
New York, NY 10018
EFTA00017094


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=== Page 1 ===
From:
To:
(USANYS)"
Cc: "
Subject: Epstein/ Austria
Date: Mon, 22 Jul 2019 16:28:13 +0000
- The Austrian Embassy has just contacted me to ask whether they can be provided
information regarding the alleged Austrian passport that Epstein had in his possession. Is there
anything we can share in this regard? Thanks,
EFTA00016173


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=== Page 1 ===
From:
To:
Subject: Relativity Review - US V. Epstein (SW Returns) - USGME01782221
Date: Wed, 18 Aug 2021 16:40:30 +0000
https://d1pe.nss.pae.com/Relativity/go?id=2370462-2823018
EFTA00015875


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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
EFTA00015139


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=== Page 1 ===
From: Joe Nascimento
To:
"
)"
Cc:
)"
"
,
)"
Subject: Re:
)
- Epstein
Date: Fri, 12 Jul 2019 01:10:21 +0000
Sounds good, see you at 12.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
t.
f.
e.
www.crimlawfirm.com
On Jul 11, 2019, at 9:07 PM,
)
wrote:
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are here, and we will
meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
EFTA00014318

=== Page 2 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating logistics, and we will
let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0><x-
apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
)
<mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
EFTA00014319

=== Page 3 ===
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0><x-
apple-data-detectors://2/0> Avenue<x-apple-data-detectors:.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com-http://www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
<mailto:
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-apple-data-
EFTA00014320

=== Page 4 ===
detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http//www.crimlawfirm.com-<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
A
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com-http/www.crimlawfirm.com
From:
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
)"
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on Tuesday - you can
reach us at
, or we can also call you then if that's easier, whatever you prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)
EFTA00014321

=== Page 5 ===
<mailto:
mailto:
Subject: Re:
) - Epstein
Hi
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com-http://www.crimlawfirm.com/
On Jul 7, 2019, at 4:04 PM,
)
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our
schedules may be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can
schedule it for before you meet with
,
if that's helpful. Or if you'd like to talk sooner, we could
schedule a time later today, or check in tomorrow about a possible afternoon discussion. Please let us know
what you prefer, and we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
)
<mailto:
<mailto:
Subject:
)
- Epstein
EFTA00014322

=== Page 6 ===
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
>mailto:
<mailto:
<mailto:
<mailto:
mailto:
Cc:
<mailto:
mailto:
Subject:
) - Epstein
My former partner, Alan Ross, represented
, prior to his passing in
2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting
up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com<http//www.crimlawfirm.com/
EFTA00014323


c1: EFTA00015589
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015589.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Travel approval request
Date: Wed, 10 Jul 2019 11:31:50 +0000
Importance: Normal
Good morning
I was out of the Office yesterday, but I'll get this booked right away. Thanks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, July 09, 2019 10:11 PM
To:
Subject: FW: Travel approval request
Hi
It's still up in the air whether l'll be on this trip to Florida later this week, but could you please create a travel authorization
just in case? Thank you!
From:
Sent: Tuesday, July 09, 2019 19:38
To:
Subject: Travel approval request
Traveler,
Please have your legal asst. create a travel auth. in E2 for
to officially fund & approve today. Thanks
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_layouts/15/WopiFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%2OLibrary/TravelStateTaxExemption.pdf&action=default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
EFTA00015589

=== Page 2 ===
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
for approval.
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
From:
Sent: Tuesday, July 09, 2019 2:09 PM
To:
V.
Cc:
is
Subject: RE: travel approval request
Thanks!
From:
Sent: Tuesday, July 9, 2019 2:08 PM
To:
is
Cc:
Subject: RE: travel approval request
Approved for the travel and necessary conference room.
Thank you for correctly setting your priorities.
From:
Sent: Tuesday, July 09, 2019 2:00 PM
To:
>;
Cc:
Subject: RE: travel approval request
Hi
In connection with the Epstein case (2018R01618), we would like to request permission to travel this week for victim
interviews in Palm Beach, Florida. Our agents will be there starting tomorrow, through Sunday, and our current plan is for
some combination of our team
(
and me) to be there from Thursday*** through Sunday. And also same as
last time, we'd like to ask permission to reserve a conference room at the hotel for those four days.
Thanks very much,
***we would never miss the BBQ.
From:
Sent: Wednesday, June 12, 2019 3:28 PM
EFTA00015590

=== Page 3 ===
To:
Cc:
Subject: RE: travel approval request
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
)
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
>;
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
EFTA00015591

=== Page 4 ===
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
-
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00015592


c1: EFTA00014536
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014536.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: Re: Briefing in Florida regarding whether the Florida NPA extends to New York
Date: Fri, 26 Jul 2019 02:12:59 +0000
Happy to chat tomorrow. Name your time that's convenient for you.
- sent from my iPhone - please excuse brevity and errors.
On Jul 25, 2019, at 8:07 PM,
)
wrote:
Thank you for sending us these materials, we appreciate being able to stay up to date, and we'll continue to keep an eye
on the docket for submissions that may be relevant for our investigation.
Separately, might you be available for a quick call sometime tomorrow (Friday) or next week? No rush or emergency,
but we wanted to talk with you about a question in connection with your expertise on the CVRA generally. At your
convenience.
thanks,
From:
Sent: Thursday, July 25, 2019 13:01
To:
Cc:
is
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
Hi
I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See attached.
You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies in the case
that relate solely to Florida crimes and Florida victims because the NPA only covers Florida.
We filed our reply brief on remedies on Tuesday - and that should have brought all briefing on remedies for the CVRA
violation to a close. But yesterday Epstein's lawyer (Marty Weinberg) filed a motion for a sur-reply. See attached. In
point (a) on page 2, he argues that he should have an opportunity to file a sur-reply discussing, among other things, the
scope of the NPA. On Monday, we will be filing an opposition to Weinberg extending the briefing further. It appears
that Judge Marra is poised to rule rapidly on the motion for a sur-reply, as he asked for us to respond quickly.
I wanted to make you aware of these developments. My clients were told back in 2013 that the NPA did not extend to
New York or other jurisdictions - and that is the point we are making to Judge Marra.
for Jane Doe 1 and 2
EFTA00014536

=== Page 2 ===
(fax)
You can access my publications on
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message.
is admitted to
the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
EFTA00014537


c1: EFTA00014291
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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Voucher for Trip 10643456-2 is late
Date: Tue, 01 Oct 2019 04:02:28 +0000
Importance: Normal
Dear
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
Trip ID: 10643456-2
Traveler name:
Destination: Santa Monica
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Trip Dates: 2019-09-17 - 2019-09-20
Current status: Authorization Approved
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
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Reference ID# V0013
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.
EFTA00014291


c1: EFTA00017042
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017042.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Gary Bloxsome
Cc:
)"
Daniel Cundy
"Jennifer
,
Richardson"
Subject: RE: U.S. Department of Justice investigation
Date: Tue, 04 Feb 2020 18:23:11 +0000
Inline-Images: image001.jpg; image002.jpg
Gary,
You are aware of our position, and we do not believe any further rehashing of our prior conversations is productive at this
point. That said, we can confirm that it is our standard practice to refrain from publicly commenting on the substance of any
witness interview, and we intend to abide by that practice in this case. Beyond that, we can make no commitments. Please
advise as to whether Prince Andrew will agree to be interviewed and, if so, when such interview will take place.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Monday, February 03, 2020 10:46
To:
Cc:
is
>; Daniel Cundy
Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear
Thank you for your email of 30 January 2020.
On 10 January 2020 you personally assured me that any contact between the Duke of York and the DOJ was
confidential and would remain confidential within the investigation team in the DOJ and FBI. You said: "We don't
intend to share either the contents or the existence of the conversation beyond our chain of command in the DOJ. As
well as our partners at the FBI. It is confidential within the investigation team and our supervisors." The note I made
of what you said about the confidentiality of the interview process is as follows: "We do not publicise the content or
existence of any of our interviews. We can't guarantee that anyone might not share it with some other person or it
might be shared with other individuals who might come to have knowledge of its existence, but our office does not
advise the press of the interview and doesn't advise other interviewees of the fact the interview has taken place or
the contents of those discussions. For example, it was reported widely that our office was attempting to interview
your client months ago which was inaccurate. We have been working on this request for several weeks now and it
has not hit the press. That is consistent with our processes. We take confidentiality very seriously."
At no point did you suggest that, because of a press statement made on behalf of the Duke in November 2019, you
or your colleagues in the investigation team would feel able to provide a public commentary on the DOJ's views on
EFTA00017042

=== Page 2 ===
the degree of cooperation provided by the Duke. DOJ's first contact of any kind with the Duke was in early January
2020, and the first mention of any request for consideration of an interview came solely from you.
I object to your wholly inaccurate statement that the Duke has created a public misimpression. The Duke has made it
clear that he has a strong desire to cooperate fully with the ongoing investigation by the DOJ. The communications
between us were intended to enable him to provide that co-operation. In order for this process to continue, I need
to emphasise that we regard the confidential treatment of all contacts between the DOJ and the Duke as essential.
We do not wish to have any public pronouncements on what we regard as a voluntary and confidential process.
Please confirm that any further communications in connection with the requested voluntary interview will be
treated as wholly confidential and the DOJ will offer no further commentary on the Duke's co-operation.
Best
Gary Bloxsome
Gary Bloxsome
Partner
RANKED IN
Chambers
LEGAL
Blackfords LLP
UK
500
www.blackfords.com
2020
TOP TIER
Leading Firm
2020
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint
Walk, Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 30 Jan 2020, at 23:51,
wrote:
External email: is it safe to open attachments and links?
Gary,
On November 20, 2019, Prince Andrew publicly offered to cooperate with our investigation into Jeffrey Epstein's crimes,
stating in a press release: "Of course, I am willing to help any appropriate law enforcement agency with their
investigations, if required." In early January 2020, our Office responded to the Prince's public offer by contacting you to set
up the interview that the Prince claimed to be willing give us. More than three weeks after our initial contact with you, we
still had no date for an interview, nor did we even have a commitment from you that the Prince in fact would agree to an
interview.
On January 27, 2020, at a press event held by Safe Horizon to which Mr. Berman was invited, Mr. Berman was asked: "As
part of [the Epstein] investigation have you reached out to interview Prince Andrew, and has he been cooperative?"
EFTA00017043

=== Page 3 ===
Mr. Berman responded: "Ordinarily, our office doesn't comment on whether an individual cooperates or doesn't cooperate
with our investigation. However, in Prince Andrew's case, he publicly offered, indeed in a press release, offered to
cooperate with law enforcement investigating the crimes committed by Jeffrey Epstein and his coconspirators. So I think in
that context, it's fair for people to know whether Prince Andrew has followed through with that public commitment. So let
me say that the Southern District of New York and the FBI have contacted Prince Andrew's attorneys and requested to
interview Prince Andrew and to date, Prince Andrew has provided zero cooperation."
Mr. Berman's statement corrected a public misimpression - created by the Prince himself - that the Prince is cooperating
with our investigation.
As soon as the Prince commits to a date for the interview that he so publicly offered to us more than two months ago, we
would be prepared to announce that he has agreed to be interviewed.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Tuesday, January 28, 2020 11:59
To:
)
Cc:
is
>; Daniel Cundy
Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear
Thank you for your email response claiming that US Attorney Berman's statements were factually accurate and
did not create a misleading impression.
We only have access to edited video and newspaper reporting of what the US Attorney said. Those reports
suggest the US Attorney described the position of the Duke of York and his advisors in misleading, condemnatory
and prejudicial terms. US Attorney Berman is quoted as having stated there has been "zero co-operation". This is
not an accurate statement of the position. The following are also false statements ascribed to Mr Berman and to
the DOJ/FBI: "F.B.I. agents and federal prosecutors in New York reached out to his lawyers and asked to
interview him. There was no response at all, according to three people familiar with the investigation." (New York
Times 27.01.20) and "Geoffrey Berman, a US attorney, said federal prosecutors and the FBI had asked to
interview Prince Andrew about the late paedophile billionaire, but had been met with a wall of silence "(The
Telegraph 28.01.20).
Please provide us with an accurate record of the statements made by The US Attorney and/or the DOJ/FBI
including a transcript of any relevant questions and answers.
We note from your email that you have not provided any response to our request that you confirm that the DOJ
will not be making any further public statements about the Duke of York. We had understood from our
conversations with you and from the rules governing media relations that DOJ personnel and the US Attorney
would not comment on the nature or progress of any grand jury investigation and in particular would not
comment on the willingness of any Subject to make a voluntary statement to the DOJ. We ask you to confirm
that there will be no further public comment on any contact between the Duke of York and the DOJ.
Kind regards
EFTA00017044

=== Page 4 ===
Gary
Gary Bloxsome | Partner
<image001.jpg> <image002.jpg>
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 27 Jan 2020, at 22:59,
wrote:
External email: is it safe to open attachments and links?
Gary,
Our understanding is that U.S. Attorney Berman made a factual statement in response to a specific question that
suggested the Duke of York either would or was cooperating, and he responded that to date he has not in fact provided
cooperation with our investigation. That is, he corrected the record generally in a factually accurate statement; I don't
believe this would create a misleading impression. I appreciate that you have advised us that your client has a desire to
cooperate, and we look forward to hearing from you when he has made a determination as to whether he is in fact
willing to speak with us.
Regards,
From: Gary Bloxsome
Sent: Monday, January 27, 2020 13:44
To:
Cc:
is
>; Daniel Cundy
Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
The press are reporting that Geoffrey S. Berman, the United States Attorney for the Southern District of New York has
disclosed what we understood were confidential communications between us and
and
It has also been suggested that Geoffrey S. Berman has stated that the Duke of York has not co-operated with the
Southern District. As you know we have made it very clear that the Duke of York has a strong desire to cooperate with
the ongoing investigation by the DOJ and we are trying to reach a position where we are able to advise him to do so.
We are concerned about the misleading impression that has been created and the effect this has on our ability to advise
the Duke to proceed with any voluntary co-operation. Please confirm that the DOJ will not be making any further public
statements on this topic.
Thank you.
EFTA00017045

=== Page 5 ===
Gary Bloxsome
Gary Bloxsome
Partner
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 22 Jan 2020, at 17:34,
wrote:
External email: is it safe to open attachments and links?
Gary,
We've received your response. We look forward to hearing whether the Duke of York is willing to speak with us.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 22, 2020 11:35
To:
Cc:
is
>; Daniel Cundy
Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
We are very grateful for your offer of assistance. At present we do not believe you can help us but we would welcome
a real-time conversation once we have achieved some of the more immediate preliminary tasks, including the need to
gather information from the Royal Household and others.
Best
Gary Bloxsome Partner
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00017046

=== Page 6 ===
On 20 Jan 2020, at 18:52,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
Thank you for your response. It would be useful for us if you were able to help us understand the nature of the issues
and procedures with which you are dealing, particularly as it sounds like it will take at least a couple additional weeks
to address even minor preliminary issues, which suggests likely additional subsequent time to handle further
processes-and without a response to the question of whether he is willing to speak with us, separate from a general
desire to cooperate. Our investigation is moving forward expeditiously and so we would be grateful for some
understanding of the relevant issues (especially, though not exclusively, to the extent we may be able to assist in their
resolution) and would be happy to speak via phone if a real-time conversation would be more conducive to that
discussion.
thank you,
From: Gary Bloxsome
Sent: Monday, January 20, 2020 11:23
To:
Cc:
is
>; Daniel Cundy
Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email. The Duke of York has made it clear to us that he has a strong desire to cooperate fully with
the ongoing investigation by the DOJ.
It is our responsibility to deal with the various issues and procedures that arise here that will need to be addressed to
enable him to do so. We should be able to deal with at least some of the minor preliminary issues in the next two
weeks and we will update you on our progress once we have done so.
Regards,
Gary
Gary Bloxsome
Partner
<image001.jpg> <image002.jpg>
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk,
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
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Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 18 Jan 2020, at 01:06,
wrote:
External email: is it safe to open attachments and links?
Gary,
We write to follow up on our phone conversation of a week ago. Could you please advise regarding status, in
particular the initial question, separate from any logistics, of whether you expect your client will be willing to speak
with us? And of course please let us know if any additional information would be useful to you.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 08, 2020 07:38
To:
Cc:
i
>; Daniel
Cundy
; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Friday 10th January at 1400(LDN) time is fine.
Please forward dial in details.
Kind regards
Gary
Gary Bloxsome Partner
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
EFTA00017048

=== Page 8 ===
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 7 Jan 2020, at 18:56,
wrote:
External email: is it safe to open attachments and links?
Gary,
We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available at
9:00 local time for us (which I believe would be 14:00 your time). If that works, we can plan to call you at your
office line unless you'd prefer we use another number or a conference line.
thank you,
From: Gary Bloxsome
Sent: Tuesday, January 07, 2020 11:20
To:
Cc:
is
>; Daniel
Cundy
; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
Kind regards.
Gary
Gary Bloxsome Partner
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 4 Jan 2020, at 01:38,
wrote:
EFTA00017049

=== Page 9 ===
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Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally, in
connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to
request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to
inquire about his relationship and communications with Jeffrey Epstein and his associates, as well as certain
allegations that have arisen publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law
enforcement channels, we understand we may also alternatively inquire directly with counsel, when an
individual has legal representation. Given your representation, we are inquiring directly with counsel in the first
instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were
seeking as a threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
Cc:
is
>; Daniel
Cundy
Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
Gary Bloxsome
Partner
EFTA00017050

=== Page 10 ===
Blackfords LLP
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jan 2020, at 18:54,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of
Justice, Southern District of New York. We have been advised that you currently represent HRH The Duke of
York. Could you please advise whether that is correct? We - my colleagues
and I
- can be reached anytime at these email addresses, or please let us know if you would prefer to set up a time
to discuss via phone.
Regards,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: Linesheets
Date: Fri, 04 Jun 2021 01:50:38 +0000
Attachments: 06.03.21.pdf
Hi,
Here are the linesheets for today.
EFTA00016602


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=== Page 1 ===
From:
To:
Subject: protective order
Date: Wed, 24 Jul 2019 20:18:01 +0000
Attachments: 2019-07-24,_JE_protective_order_for_discovery_(RMB).docx
The new language is highlighted-let me know if you're good with this to go out.
Thanks!
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: RE: Action shot from Florida Daily Post
Date: Mon, 22 Jul 2019 20:41:43 +0000
https://floridadailypost.com/deemed-dangerousepstein-denied-bail-sex-abuse-case/
From:
(USANYS)
Sent: Monday, July 22, 2019 3:06 PM
To:
Subject: Re: Action shot from Florida Daily Post
Can you forward me the article?
On Jul 22, 2019, at 2:38 PM,
wrote:
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
<Deemed-Dangerous-Epstein-Denied-Bail-in-Sex-Abuse-Case.jpg>
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=== Page 1 ===
From:
To:
Subject: SecureMail Encryption Response
Date: Mon, 09 Sep 2019 21:41:29 +0000
Your message was successfully encrypted.
Message Details:
From:
To:
Subject: Epstein File - Redactions
EFTA00017093


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=== Page 1 ===
From:
To:
Subject: Arrest Today
Date: Thu, 02 Jul 2020 12:50:53 +0000
Just a heads up that we are unsealing an indictment this morning against Ghislane Maxwell, an associate of Jeffrey
Epstein, charging her with facilitating his abuse of minors. She was arrested in New Hampshire this morning, so the
presentment will not be in SDNY. She will not appear in SDNY today. Let me know if you have any issues.
Chief, Criminal Division
United States Attorney's Office, SDNY
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 502 Filed 11/24/21 Page 1 of 2
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/24/21
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As noted in this Court's prior order, trial in this case will commence on November 29,
2021. Dkt. No. 330. The trial will take place in Courtroom 318 of the United States District
Court for the Southern District of New York, Thurgood Marshall U.S. Courthouse at 40 Foley
Square, New York, New York. In accordance with its prior Order, the Court will ensure access
for alleged victims and members of the Defendant's family. Dkt. No. 344.
The Federal Rules of Criminal Procedure prohibit the broadcasting of federal judicial
criminal proceedings from the Courtroom. See Fed. R. Crim. P. 53; see also https://nysd.us
courts.gov/covid-19-coronavirus. However, as indicated below, consistent with the District's
COVID-19 protocols, the Court will facilitate substantial public and press access at the
Courthouse.
First, consistent with the District's COVID-19 distancing requirements, a number of pool
reporters and members of the public will be permitted in the courtroom proper as managed by the
District Executive's Office.
Second, press will also be able to access the trial in dedicated overflow courtrooms for
the press. Questions about press access should be directed to the District Executive's Office.
Please email Media_Inquiries@nysd.uscourts.gov, or call (212) 805-0513.
1
EFTA00016515

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 502 Filed 11/24/21 Page 2 of 2
Third, members of public will also be able to access the trial in overflow courtrooms in
the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio
feeds of the proceeding. There will be substantial seating capacity available in the overflow
rooms for members of the public. If capacity is reached, no additional persons will be admitted.
Questions about public access should be directed to the District Executive's Office-(212) 805-
0500.
Per the S.D.N.Y. Response to COVID-19, anyone who appears at any S.D.N.Y.
courthouse must complete a questionnaire on the date of the proceeding prior to entering the
courthouse. All visitors must also have their temperature taken when they arrive at the
courthouse. Only persons who meet the entry requirements established by the questionnaire and
whose temperatures are below 100.4 degrees will be allowed to enter the courthouse. All visitors
must wear a mask that covers the person's nose and mouth. Bandannas, gaiters, and masks with
valves are not permitted. If a person does not have an approved mask, a screener will provide
one. Anyone who fails to comply with the COVID-19 protocols that have been adopted by the
Court will be required to leave the courthouse. There are no exceptions. For more information,
please see https://www.nysd.uscourts.gov/covid-19-coronavirus.
so ORDERED.
Dated: November 24, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
)"
Cc: Andrew Tomback
Subject: RE: Epstein NY property
Date: Thu, 16 Jul 2020 14:24:56 +0000
Marc,
Any time in that range works for us - if you send a dial-in, we'll call whenever you set it for. Thanks, and speak with you
then.
From: Weinstein, Marc A.
Sent: Thursday, July 16, 2020 10:04
To:
is
>;
Cc: Andrew Tomback
Subject: Epstein NY property
Would you have time for a call today for an update on the NY property? If so, would something between 1:00-1:45 work?
Thanks,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York, NY 10004-1482
Office
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Mark Epstein
Date: Thu, 24 Oct 2019 16:32:29 +0000
No problem, and of course if she wants us instead we'll reach out.
From:
Sent: Thursday, October 24, 2019 11:56
To:
Cc:
Subject: RE: Mark Epstein
Thanks. Good call - I had those guys reach out.
From:
Sent: Thursday, October 24, 2019 9:31 AM
To:
Cc:
Subject: RE: Mark Epstein
I think it's possible she may be reaching out in connection with the death investigation-do you have a sense of what she
wants? Happy to call her back in the first instance, just wanted to flag it in case you'd rather have the other team respond
initially-whatever you prefer.
From:
Sent: Thursday, October 24, 2019 09:29
To:
Subject: Mark Epstein
I forgot to convey to you last week that Stacey Richman had left me a vm re her client Mark Epstein. She left me another
vm this morning. Could you guys call her back?
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=== Page 1 ===
From:
To:
Cc:
)"
Subject: RE: out of curiosity
Date: Thu, 09 Apr 2020 14:33:49 +0000
Well this is all baffling but I really appreciate knowing it's not just Epstein. Thanks guys.
From:
Sent: Thursday, April 09, 2020 10:27
To:
Cc:
Subject: Re: out of curiosity
I got a deadline of next week for a memo the timing of which has no possible significance and for which, I told them,
some additional things we are working on that cannot be completed by next week could be important.
On Apr 9, 2020, at 10:19 AM,
wrote:
Yeah suddenly an AMI pros memo became very urgent last week.
On Apr 9, 2020, at 10:12 AM,
wrote:
To the extent anybody in this small group is willing to share, are any of you folks' teams / cases getting significant
pressure from the chiefs on memos or other written product this week, whether for the brass or otherwise? I'm just
curious whether it's just the Epstein case (where we're getting near-daily prodding about imminent deadlines for
memos that are both extremely time-intensive and also couldn't possibly be acted upon for weeks, given the
circumstances of the world) or if it's something broader in the unit. I just sent the chiefs a pretty crabby email about
being bugged daily about lengthy, detailed work product and it made me wonder whether this is a trend or an isolated
incident.
More importantly, hope y'all and families are all staying healthy
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: RE:
Emails
Date: Mon, 16 Dec 2019 16:46:22 +0000
Inline-Images: image001.png
Saved here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Witnesses & Cooperators\
Emails
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=== Page 1 ===
Mod AO 442 (09/13) Arrest Warrant AUSA Name & Telno:
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
V.
)
)
Case No.
)
)
20cr330
)
Ghislaine Maxwell
)
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested) Ghislaine Maxwell
,
who is accused of an offense or violation based on the following document filed with the court:
Indictment
Superseding Indictment
Information
Superseding Information
Complaint
Probation Violation Petition
Supervised Release Violation Petition
Violation Notice
Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (conspiracy to entice minors)
Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
Title 18, United States Code, Section 371 (conspiracy to transport minors)
Title 18, United States Code, Sections 2423(a) and 2 (transportation of a minor)
Title 18, United States Code, Section 1623 (perjury)
his Margaret Sun
Date:
06/29/2020
Issuing officer signature
City and state:
White Plains, NY
Hon. Lisa Margaret Smith, U.S. Magistrate Judge
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on (date)
at (city and state)
.
Date:
Arresting officer's signature
Printed name and title
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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc
Subject: [EXTERNAL] Re: 20cr330 - US V. Maxwell
Date: Fri, 15 Oct 2021 17:55:58 +0000
Good afternoon-
Names followed by phone numbers indicate individuals planning to attend the 10/21 teleconference.
Names followed by 11/1 indicates attendance at the in-person conference.
Counsel for Ghislaine Maxwell
(Each lawyer may each speak but_only_per issue)
Bobbi C. Sternheim, Esq.
(10/21 & 11/1)
Christian Everdell, Esq.
(10/21 & 11/1)
Laura Menninger. Esq.
(10/21 & 11/1)
Jeffrey Pagliuca. Esq.
(10/21 & 11/1)
Ann Lundberg (paralegal)
(11/1 only)
Family/Friends
Ian Maxwell
Kevin Maxwell
Pandora Maxwell
Philip Maxwell
Anne Holve
Katie Vaughan Edwards
Brian Basham -
Isabel Maxwell
EFTA00016726

=== Page 2 ===
Christine Maxwell
Leah Saffian
Jeff Roth
Please contact me with any questions.
Thank you.
Bobbi
Please note my new office address and preferred email address:
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.
On Oct 13, 2021, at 8:27 PM,
wrote:
Counsel:
The Court is currently in the process of planning logistics for the October 21 teleconference and the
in-person November 1 pretrial conference.
The Court requests that each party provide their best and current estimate of the number of case
related participants who will attend each proceeding (including attorneys, paralegals, victims, and
family members). Please provide this information via email no later than Friday, October 15 at 10:30
a.m.
The Court also requires additional information specific to each conference.
For the October 21 teleconference, the Court will docket a public access dial-in number. There will
be a separate dial-in line for party participants to ensure access. Please provide the telephone
numbers of the attorneys, and any victims and Defendant family members who will attend. Also
please specify the name and number of those who plan to speak during the conference so that they
can be unmuted. Bear in mind that Judge Nathan will enforce a one attorney speaking per issue rule.
EFTA00016727

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For the November 1 in-person conference, the District Executive's Office requires counsel to provide
the number of people who plan to attend for their party (including attorneys, paralegals, victims, and
family members) and the vaccination status of each person. This will help the Court plan in
accordance with the District's COVID-19 protocols.
Please provide the conference-specific information via email as soon as possible but no later
than Monday, October 18 for the information regarding the October 21 teleconference, and no later
than Friday, October 22 for the information regarding the November 1 conference.
Sincerely,
Chambers of the Hon. Alison J. Nathan
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=== Page 1 ===
From: Chris Dilorio
To:
EFTA00015194

=== Page 2 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Thu, 02 May 2019 21:35:59 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tells-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Diiorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
To:
EFTA00015195

=== Page 3 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) | Seeking
Alpha - Stock Market Insights I Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
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=== Page 4 ===
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, April 14, 2019 1:04 PM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
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=== Page 5 ===
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-ii-joins-wilmerhale
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
EFTA00015198

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SEC.gov
| Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
To:
Subject: Apollo/ Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0.
Florida?
Pennsylvania?
or
Canada?
EFTA00015199

=== Page 7 ===
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.html
EFTA00015200

=== Page 8 ===
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
---
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
EFTA00015201

=== Page 9 ===
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00015202


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=== Page 1 ===
JANE DOE #3 (
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 59
12/6/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 60
12/12/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 64
12/14/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 71
12/20/04
Conspiracy to entice a minor to
engage in prostitution
O.A. 79
1/6/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 83
1/14/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 94
2/4/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 100
2/10/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 102
2/21/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 104
2/24/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 112
3/17/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 118
3/30/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 125
4/8/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 129
4/26/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 132
5/19/05
Conspiracy to entice a minor to
engage in prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 3
JANE DOE #3
EFTA00016019

=== Page 2 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
Ct 7
12/6/04
EPSTEIN
Enticement of a minor to engage in
6/29/05
prostitution
Ct. 32
12/13/04
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 35
1/6/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 36
1/14/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 37
2/3/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 38
2/10/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 39
2/21/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 40
2/24/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 42
3/18/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
Ct. 43
3/31/05
EPSTEIN
Travel to engage in illicit sexual
conduct
JEGE
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 2 OF 3
JANE DOE #3
EFTA00016020

=== Page 3 ===
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
Ct. 44
4/8/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 45
4/27/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 46
5/6/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 47
5/19/05
EPSTEIN
Travel to engage in illicit sexual
conduct
HYPERION
Ct. 51
12/6/04 -
EPSTEIN
Recruiting, enticing, providing, or
6/2/05
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 #3
EFTA00016021


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=== Page 1 ===
From:
"
)"
To:
)"
(USANYS)"
(USANYS)"
i
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
)"
)"
Subject: RE: letter to Epstein estate trustees' counsel
Date: Sat, 25 Jul 2020 20:13:50 +0000
Great, thanks. We'll send it shortly.
From:
Sent: Saturday, July 25, 2020 16:12
To:
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
Subject: RE: letter to Epstein estate trustees' counsel
Yes, please do.
Many thanks.
From:
Sent: Saturday, July 25, 2020 12:26 PM
To:
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
Subject: RE: letter to Epstein estate trustees' counsel
No issues with these edits. Okay for us to send with those incorporated?
thanks,
From:
Sent: Saturday, July 25, 2020 11:31
To:
-
is
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
)
Subject: RE: letter to Epstein estate trustees' counsel
Thanks
Attached are some suggested comments to the letter.
Feel free to give me comments.
EFTA00015847

=== Page 2 ===
From:
Sent: Thursday, July 23, 2020 5:12 PM
To:
)
i
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>;
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
EFTA00015848


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=== Page 1 ===
From: H Dohn Williams Jr.
To:
Subject: Jeffrey Epstein
Date: Fri, 19 Jul 2019 18:34:48 +0000
Attachments: epstein.pdf
H. Dohn Williams Jr.
cell & text messages
EFTA00014614


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=== Page 1 ===
From:
)"
To:
"
Cc:
)"
)"
Subject: RE: Subpoena 20 Mag. 6216
Date: Tue, 23 Jun 2020 18:01:41 +0000
Attachments: 2020-06-12,_subpoena_to_Amazon_(for_service).pdf
Been a while since we last corresponded - we hope you're well, given the circumstances of the world. We wanted to
reach out because we served a subpoena on Amazon on June 12, and we'd like to ask to expedite the response, at least as
to shipping / delivery information for the relevant individual. The subpoena is attached for your reference, and it would
be extraordinarily helpful if we could get at least that information by the end of the week (which is the deadline on the
subpoena, though obviously we ordinarily are understanding of some additional time being necessary). Please let us
know? And we're happy to discuss if that would be useful.
thanks,
From:
Sent: Thursday, August 15, 2019 14:44
To:
Subject: Automatic reply: Subpoena CRIM1031692
I'm traveling for business today (8/15) so my responses might be delayed. If your inquiry involves a law enforcement
information request, please contact
(
),
(
), and/or
.
EFTA00017701


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: Call re Maxwell
Date: Mon, 05 Apr 2021 18:25:08 +0000
Hi
We would like to schedule a call to chat about an issue that came up when I was reviewing the physical evidence from the
Epstein file on Friday.
and I are all free tonight from 6pm to 7pm, tonight from 7:30pm to 8pm, or tomorrow
from 1pm to 3pm. Is there a time in any of those windows when we could have a call, please?
Thanks,
EFTA00015722


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: P.S.
Date: Mon, 02 Jun 2008 23:01:57 +0000
Importance: Normal
Hi
- Apparently some fairly reputable news sources are reporting that Epstein has moved significant assets
off shore and intends to flee. We are going to try to find out if they have any legitimacy.
Assistant U.S. Attorney
Phone
Fax
EFTA00014162


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=== Page 1 ===
1
j782epsC kjc
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
UNITED STATES OF AMERICA,
New York, N.Y.
3
V.
19 Cr. 490 (RMB)
4
JEFFREY EPSTEIN,
5
Defendant.
6
X
Conference
7
July 8, 2019
1:20 p.m.
8
9
Before:
10
HON. HENRY B. PITMAN,
11
Magistrate Judge
12
13
APPEARANCES
14
GEOFFREY S. BERMAN
United States Attorney for the
15
Southern District of New York
BY:
16
17
Assistant United States Attorneys
18
STEPTOE & JOHNSON, LLP
Attorneys for Defendant
19
BY: REID H. WEINGARTEN
20
MARTIN G. WEINBERG
Attorney for Defendant
21
MARC FERNICH
22
Attorney for Defendant
23
Also Present:
24
Special Agent
FBI
25
Detective
, NYPD
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015606

=== Page 2 ===
2
j782epsC kjc
1
(Case called)
2
THE DEPUTY CLERK: Counsel, please state your name for
3
the record.
4
Good afternoon, your Honor. For the
5
government,
,
, and
.
6
With us are Special Agent
of the F.B.I. and
7
Detective
,
NYPD task force officer.
8
THE COURT: Okay.
9
MR. WEINGARTEN: Good afternoon, your Honor. For
10
Jeffrey Epstein, Reid Weingarten from the law firm of Steptoe &
11
Johnson.
12
MR. WEINBERG: Good afternoon, your Honor. Martin
13
Weinberg. I'm an attorney from Boston, Massachusetts; and,
14
with your Honor's permission, I will be filing a pro hac vice
15
to represent Mr. Epstein.
16
THE COURT: Okay.
17
MR. FERNICH: Good afternoon, your Honor. Marc
18
Fernich, New York, New York, also for Mr. Epstein.
19
THE COURT: All right. I have spoken to Judge Berman.
20
The matter has been referred to me for the initial appearance,
21
arraignment, and bail.
22
Mr. Epstein, my name is Magistrate Judge Pitman. The
23
purpose of this proceeding is to inform you of certain rights
24
that you have, to inform you of the charges against you, to
25
consider whether counsel should be appointed for you, and to
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015607

=== Page 3 ===
3
j782epsC kjc
1
decide under what conditions, if any, you should be released.
2
Can I have the date and time of arrest, please?
3
MR.
Yes, your Honor. The defendant was
4
arrested on Saturday, July 6, at approximately 5:30 p.m.
5
THE COURT: Thank you.
6
Mr. Epstein, you have the right to remain silent. You
7
are not required to make any statements. Even if you have made
8
any statements to the authorities, you need not make any
9
further statements. Anything you do say can be used against
10
you.
11
You have the right to be released, either
12
conditionally or unconditionally, pending trial unless I find
13
that there are no conditions or combination of conditions that
14
would reasonably assure your presence in court and the safety
15
of the community.
16
You have the right to be represented by counsel during
17
all court proceedings, including this one, and during all
18
questioning by the authorities. If you cannot afford an
19
attorney, I will appoint one to represent you.
20
It is my understanding that you are being represented
21
by retained counsel. I want to advise you that the right to
22
the appointment of counsel is an ongoing right that you possess
23
throughout these proceedings. If at any time you are unable to
24
continue with retained counsel for financial reasons, you can
25
apply to the court at any time for the appointment of counsel.
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 4 ===
4
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1
Do you understand that?
2
THE DEFENDANT: Yes, your Honor.
3
THE COURT: Mr. Epstein, you are charged in an
4
indictment in two counts.
5
Count One charges you with a sex trafficking
6
conspiracy in violation of Title 18 United States Code § 371.
7
Count Two charges with you with the substantive
8
offense of sex trafficking in violation of Title 18 United
9
States Code $ 1591.
10
Mr. Weingarten, are you going to be lead counsel here
11
today?
12
MR. WEINGARTEN: Yes, your Honor.
13
THE COURT: Mr. Weingarten, have you received a copy
14
of the indictment?
15
MR. WEINGARTEN: Yes, your Honor.
16
THE COURT: Have you reviewed it with your client?
17
MR. WEINGARTEN: Yes, your Honor.
18
THE COURT: Do you waive its reading?
19
MR. WEINGARTEN: Yes, your Honor.
20
THE COURT: Mr. Epstein, how do you plead?
21
THE DEFENDANT: Not guilty, your Honor.
22
THE COURT: Because the defendant has been indicted,
23
there will be no preliminary hearing, and that takes us to the
24
question of bail. In that regard, I have received the Pretrial
25
Services report. I have also received a letter from the
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 5 ===
5
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1
government dated July 8, 2019.
2
I take it all counsel have the same documents?
3
MR. WEINGARTEN: Yes, your Honor.
4
THE COURT: I will hear from the government first, and
5
then I will hear from defense counsel.
6
MR.
Yes, your Honor.
7
The government intends to seek detention, and I am
8
happy to explain the reasons why. Would the court prefer that
9
I speak from the table or from the podium?
10
THE COURT: Whatever your pleasure is.
11
MR.
Your Honor, the defendant poses an
12
extraordinary risk of flight and danger presented by him.
13
Given the charges and the characteristics of the defendant, he
14
simply cannot reasonably be expected to appear in court if he
15
is granted bail. Accordingly, the government joins the
16
recommendation of Pretrial Services that the defendant be
17
detained pending trial for a number of reasons.
18
Starting with the conduct alleged, the defendant is
19
charged with trafficking minors for sex acts, as the court
20
explained, in violation of 18 United States Code $ 591, and is
21
charged with a count of conspiracy to traffic minors for sex
22
acts in violation of 18 U.S.C. 371.
23
In particular, the indictment charges that the
24
defendant engaged in a years-long scheme to sexually abuse
25
underage girls, paying minor girls to themselves be abused, and
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 6 ===
6
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1
also paying certain victims to recruit other girls to be
2
subject to the defendant's sexual abuse.
3
The indictment alleges that the defendant undertook
4
this conduct at at least two locations, including his mansion
5
in Manhattan and his estate in Palm Beach, Florida. In both
6
locations, victims were initially recruited to provide massages
7
to the defendant, which would be performed nude or partially
8
nude, would become increasingly sexual in nature, and would
9
typically include one or more sex acts, including contact with
10
the victims' genitals. These victims, who were often
11
particularly vulnerable, were as young as 14, and the defendant
12
knew he was abusing underage girls. The indictment further
13
alleges that the defendant perpetrated these crimes by working
14
with others, including employees and associates who facilitated
15
these abusive encounters.
16
Regarding the defendant himself, your Honor, he is
17
extraordinarily wealthy, mobile, and unattached to the Southern
18
District of New York. He maintains at least six residences in
19
the United States and abroad, including the ownership of a
20
private island in the U.S. Virgin Islands and a residence in
21
Paris, France. Among other things, the defendant owns two
22
private jets and routinely uses them to travel abroad. He is a
23
man of nearly infinite means, your Honor; and, as set forth in
24
our submission, he has tremendous incentives to use those means
25
to flee prosecution.
SOUTHERN DISTRICT REPORTERS. P.C.
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=== Page 7 ===
7
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1
The government notes as an initial matter that this is
2
a presumption case because sex trafficking is charged; and,
3
moreover, each of the four factors to be considered in the
4
detention analysis strongly militates towards pretrial
5
detention.
6
So starting with the nature and seriousness of the
7
offense, as previously discussed, the nature and circumstances
8
of the crime are the most serious crime that this court sees.
9
The defendant is alleged to have spent years sexually abusing
10
minors in multiple locations and with dozens of victims.
11
The seriousness of the charge is also reflected in the
12
potential penalties, which include up to 45 combined years of
13
incarceration on Counts One and Two, and the likelihood of a
14
substantial period of incarceration is supported by the fact
15
that the government's evidence is strong. There are multiple
16
individual identified victims in the indictment, numerous
17
specified overt acts, and dozens of overall victims alleged.
18
In order to protect the privacy of the victims, your
19
Honor, I'm not going to go into detail about particular
20
victims, but we can say that information provided by victims
21
has been detailed, it has been credible, and it has been
22
corroborated by other witnesses and contemporaneous documents
23
and records, including from a recent search of the defendant's
24
Manhattan mansion, as I will discuss further in a moment.
25
Separately, your Honor, in just the last 36 hours,
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 8 ===
8
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1
that is, post charge, we have been contacted by multiple
2
attorneys and several additional individuals who have
3
identified themselves as victims and are interested in speaking
4
with the government, none of whom the government has previously
5
spoken with.
6
Your Honor, the defendant is 66 years old. He is
7
charged with appalling crimes, and those charges are supported
8
by significant evidence, including victim and witness testimony
9
and damning record evidence. He faces the very real prospect
10
of spending the rest of his life in prison. He has every
11
motivation in the world to flee, and he has the means to do it.
12
And I will note for the court that this is a case
13
where the government has really put its money where its mouth
14
is on the risk of flight. This district took extraordinary
15
efforts to maintain the covert status of its investigation for
16
many months due to the risk of flight of the defendant -- not a
17
single media report, not a single public statement, no appeals
18
for victims to come forward because of precisely the flight
19
risks we are discussing now.
20
Turning to the characteristics of the defendant, your
21
Honor, some individuals who face significant charges lack the
22
means to flee. Not this defendant. As set forth in the
23
government's submission, in the defendant's most recent sex
24
offender registration, he lists six residences worth tens or
25
hundreds of millions of dollars, including a residence abroad.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015613

=== Page 9 ===
9
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1
The defendant has refused to answer any questions
2
about his income or assets for the Pretrial Services report, so
3
the scope of his wealth and his assets remains entirely
4
concealed to the government and to the court. But the
5
defendant certainly has access to endless means to flee,
6
including two private jets. He has no meaningful family ties,
7
and any argument that his properties would keep him in the
8
United States ignores his ability to simply leave those
9
properties behind in favor of moving beyond the reach of U.S.
10
authorities to live off his extensive wealth abroad, extensive
11
wealth, I should add, that the court doesn't even have any
12
accounting of. He travels abroad extensively, has a residence
13
in France, and all of those factors further contribute to the
14
risk of flight.
15
With respect to danger and obstruction, again, this is
16
a presumption case, and not only is the defendant charged with
17
the sexual abuse of minors, he has previously pled guilty to
18
solicitation of an underage girl. This court knows that
19
defendants are routinely detained in this district when facing
20
such charges and that this is not an unusual position for the
21
government to take.
22
It is further concerning that there are credible
23
allegations from the prior investigation that the defendant or
24
his agents engaged in witness tampering and harassment, and in
25
fact there is evidence that he was contemplating pleading
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 10 ===
10
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1
guilty to that kind of offense in Florida. Those allegations
2
include verbal harassment, evasion of legal process, and
3
forcing off the road the father of an individual relevant to
4
that investigation.
5
THE COURT: Can you elaborate on that last point about
6
forcing somebody off the road?
7
MR.
Your Honor, what we have is the
8
record evidence from an underlying civil dispute in Florida
9
that discusses this incident and discusses it in the context of
10
a potential plea of the defendant to obstruction or harassment
11
charges. The government sets before this court that if the
12
defendant was willing to undertake such measure simply as a
13
result of an investigation, the potential for dangerous and
14
obstructive activity in an indicted case is alarming and very
15
real.
16
Despite having been previously convicted of a sex
17
offense involving an underage victim and being a registered sex
18
offender, the defendant has continued to maintain a vast trove
19
of lewd photography of young-looking women or girls at his
20
mansion. Your Honor, pursuant to judicially authorized
21
warrants, law enforcement agents searched his home on Saturday
22
and found at least hundreds, and perhaps thousands, of sexually
23
suggestive photographs of nude females, many of whom appear to
24
be underage.
25
I also want to note that the search revealed specific
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1
evidence from his home consistent with victim accounts. Even
2
the room where the abuse occurred, your Honor, the massage
3
room, was still set up in the same way it was 15 years ago,
4
with a massage table and sex paraphernalia.
5
And with respect to the photographs --
6
THE COURT: When you say the evidence was consistent
7
with victim accounts, is it limited to the massage table and
8
massage room or is there something else?
9
MR.
Descriptions of the massage room and
10
the massage table, that's correct, your Honor.
11
THE COURT: Okay. All right.
12
MR.
With respect to the photographs, your
13
Honor, some of those were found in a locked safe which also
14
held electronic disks with labels that included the words
15
"Young Miscellaneous Nudes 1" and "Girl Pics Nude."
16
Your Honor, this is not an individual who has left his
17
past behind. He is a continuing danger to the community and an
18
extraordinary risk of flight and, for those reasons, the
19
government joins the pretrial recommendation that the defendant
20
be detained pending trial.
21
THE COURT: All right. Thank you.
22
Mr. Weingarten.
23
MR. WEINGARTEN: Thank you, your Honor. I will use
24
the podium, if that's okay.
25
THE COURT: That's fine.
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1
MR. WEINGARTEN: So your Honor, I would like to start
2
by providing some context, and then I'm going to make a
3
suggestion as to how we proceed.
4
The beginning here is 2005 in Florida. That's when an
5
allegation was received by the local police that Mr. Epstein
6
was engaged in sexual conduct for money, prostitution.
7
Thereafter, there was a very sophisticated three-year
8
investigation by law enforcement, including locals and feds,
9
into Mr. Epstein's conduct. Numerous girls were interviewed,
10
employees were interviewed, and it is fair to say that a
11
significant segment of the law enforcement community in Florida
12
thought what we had in hand was simple prostitution. There was
13
no coercion. There were no threats. There was no violence.
14
And it is also fair to say that a significant portion of the
15
law enforcement community in Florida believed that a local
16
misdemeanor was the appropriate sanction.
17
Now, it is also --
18
THE COURT: Did you represent Mr. Epstein in the
19
Florida investigation?
20
MR. WEINGARTEN: No, but I'm familiar with the
21
records.
22
THE COURT: All right.
23
MR. WEINGARTEN: It is also true that there was a
24
contrary view largely taken by the feds, and what ensued was a
25
complex set of discussions and negotiations and finally an
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1
agreement, an agreement that was consummated and agreed to all
2
the way up to main justice at a very, very high level.
3
The agreement involved a plea in state court to
4
soliciting an underaged girl, which would require registration,
5
compensation paid to alleged victims, and an NPA from the feds,
6
in other words, a declination by the federal government, an
7
agreement that was approved all the way up in main justice and
8
it sure seemed like a global solution at the time to everyone
9
involved, including my client.
10
What happened since then? Mr. Epstein continued a
11
life of success, generosity, creativity and, more important, a
12
law-abiding life from 2008 forward. How do we know? Because
13
when you are in registration the way he is, every single night
14
his whereabouts are known. There is constant reporting,
15
constant monitoring, and absolutely, to our knowledge, no
16
complaints by anybody from that moment forward about his
17
conduct until we have arrived in court here.
18
Now, what has happened in court from that moment?
19
There have been lawsuits, many of them ludicrous, dismissed out
20
of hand. But when something like this happens, a lot of stuff
21
comes out of the woodwork, and there were lawsuits that
22
Mr. Epstein settled also in the normal course.
23
There was one particular litigation that leads to this
24
occasion, and that is, under the Crime Victims Rights Act, that
25
act simply says that victims have a right to be consulted by
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1
the United States, and there are alleged victims in this case
2
who complain that they were not, and there has been extensive
3
litigation in the Southern District of Florida before
4
Judge Marra on that very subject. In fact, the judge concluded
5
that the prosecutors from the Southern District of Florida did
6
not adequately notify some of the victims about the ongoing
7
discussions and the consummation of the deal and, in
8
particular, the NPA. The United States took the position that
9
they had no responsibility to do so, that they had treated the
10
victims properly, and that matter continues to this day.
11
The consequences of that matter are overwhelming,
12
because the judge suggested, I think three times, that the NPA,
13
the declination, could be voided. And we think about that for
14
a second. So a defendant negotiates what he thinks is a global
15
solution with the feds. He does his time --
16
THE COURT: Does the nonprosecution agreement in
17
Florida -- the nonprosecution agreements in the Southern
18
District routinely say they are limited to the Southern
19
District of New York.
20
MR. WEINGARTEN: Obviously --
21
THE COURT: Is there a similar provision in the
22
Florida agreement?
23
MR. WEINGARTEN: I don't want to misstate. It is not
24
before me. It is obviously going to be an important part of
25
the pretrial motions. What is for sure is that there was --
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1
the negotiation with the Southern District included
2
negotiations with main justice. What's also true is the
3
investigation extended into the Southern District of New York
4
and elsewhere in terms of girls being interviewed.
5
So obviously your question is relevant and will be
6
part of the pretrial litigation for sure. But what matters
7
here and for now is there certainly was a belief that there was
8
a global solution based upon the facts on the ground.
9
THE COURT: Have you seen the Florida nonprosecution
10
agreement?
11
MR. WEINGARTEN: Yes.
12
THE COURT: And --
13
MR. WEINGARTEN: I don't have it before me. I don't
14
want to make a specific representation and not be completely
15
accurate.
16
THE COURT: Okay. All right. Go ahead.
17
MR. WEINGARTEN: The consequences of this are huge in
18
that if in fact there is a negotiation with a defendant, the
19
defendant does his time, the defendant pays his victim, and the
20
defendant spends ten years on the registration list and
21
prosecutors don't adequately notify the victims, how in the
22
world can that deal be undone? Every prosecutor in the world
23
has to oppose that possibility. No defense attorney in their
24
right mind would negotiate a deal with that potential
25
consequence.
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1
So this is a huge problem for the department and what
2
solution ensues, and I suggest the solution that ensued is this
3
indictment. To us, this indictment is essentially a do-over.
4
The allegations are from 2002 to 2005. This is old stuff.
5
This is ancient stuff. This is the very stuff that was
6
investigated by the feds in Florida, a sophisticated three-year
7
investigation. Two of the alleged victims in this indictment
8
are from Florida. The indictment here tracks the conduct that
9
was investigated in Florida back before the agreement was
10
reached. Obviously we need to get discovery to find out just
11
how inextricably linked the investigation back in Florida is
12
with what's going on here. We do know we are talking about
13
ancient conduct. We do know we are talking about facts that
14
are from 2002 to 2005, facts that were known to the United
15
States prosecutors before they entered into the NPA, the
16
declination. This is essentially a redo. That's how it feels
17
to us. And if we are correct, that should chill the blood of
18
every defense attorney who negotiates a deal with the United
19
States.
20
In addition, we have -- the central allegation here is
21
trafficking, and obviously it is useful and relevant to make
22
inquiry as to why the trafficking law was passed. It is to
23
cover abhorrent conduct, where young girls are kidnapped, they
24
are fooled, they are forced to come usually to unfamiliar
25
places, work in brothels where they service 15, 20 guys in a
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17
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1
day. They can't leave or else their families are threatened.
2
This is dreadful conduct.
3
I remember an occasion when the Attorney General Eric
4
Holder and I think Director Comey had a press conference
5
establishing this as a law enforcement priority. Every
6
sensible person in the world would think that this is the exact
7
right thing law enforcement should do.
8
This is not this case. There was no violence. There
9
was no coercion. There was no intimidation. There is no
10
deception. The bottom line, if you take a fair look at the
11
facts of this case as alleged and in the record, you may come
12
to the conclusion there was prostitution involved and maybe a
13
lot of it, but that doesn't mean that the person involved is a
14
pedophile, a rapist or, heaven knows, a trafficker. Just --
15
THE COURT: Well, if the women involved were under 18,
16
isn't that rape?
17
MR. WEINGARTEN: My understanding --
18
THE COURT: Legally they are incapable of consent, are
19
they not?
20
MR. WEINGARTEN: Well, it could be statutory rape.
21
But what I am talking about is trafficking and why the
22
statute was passed, and obviously the statute was passed to
23
protect women from the horrors that occur in such settings, and
24
that is light years removed to what happened in this case.
25
So what about bond? I would suggest that the
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1
traditional issues that we look at, the issues involved, let's
2
start with that, we believe we have extremely powerful motions
3
relating to the government seeking two bites at the apple and
4
for due process reasons, double jeopardy reasons, we don't
5
think that will stand. We also think fundamentally what's at
6
issue here is not trafficking. That's not why the statute was
7
passed.
8
The risk to others, what we have here is at least ten
9
years post incarceration in the State of Florida of conduct
10
that has never been challenged by anyone until now. The
11
registration requirements are onerous. He is under constant
12
surveillance. Law enforcement knows, if they choose to look,
13
exactly where he is at any time.
14
The risk of flight, what is true is from the moment of
15
Judge Marra's litigation in the Southern District of Florida,
16
the defendant knew that there would be challenges to the NPA.
17
From 2013 on, there were representations made in court that
18
that challenge was ongoing, and the defendant never sought to
19
flee, never anticipated a time when he would flee, continued to
20
live his law-abiding life. So the risk of flight, I think, is
21
dramatically overstated in the government's presentation.
22
I think the traditional remedies that the court finds
23
appropriate in case after case -- a large cash bond; passport
24
relinquished; waiving extradition; a bracelet on; some form of
25
supervision that is adequate to guarantee his appearance, it
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=== Page 19 ===
19
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1
will be child's play to find that; bonds from other people,
2
surety bonds from other people.
3
Because we have not had an opportunity to see our
4
client until today and because we have just received the
5
government's submission, what we would like to do is have the
6
opportunity to sit down and put together a bail package, a
7
coherent bail package in writing and provide it to the court.
8
I would point out on the obstruction allegation --
9
THE COURT: Let me ask you this -- sorry to interrupt
10
you -- do you want to adjourn the detention hearing? Under the
11
statute, you have up to three days.
12
MR. WEINGARTEN: What I would like is to have until
13
the end of the week to provide something in writing, a specific
14
recommendation in writing.
15
THE COURT: So you want to adjourn a determination of
16
bail?
17
MR. WEINGARTEN: Yes.
18
THE COURT: Is there any objection to that from the
19
government? The defendant is detained in the interim under
20
3142(f).
21
MR. WEINGARTEN: Right.
22
MR.
Your Honor, we certainly don't object
23
if the defendant is consenting to detention with leave to make
24
a further application.
25
I think the government would like at least a brief
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1
opportunity to respond to some of those points, to the extent
2
that the defense is arguing that Mr. Epstein should be granted
3
bail as a general matter and the court is going to consider
4
those arguments.
5
THE COURT: Well, the court always considers the
6
parties' arguments.
7
But let me just come back to Mr. Weingarten for a
8
minute. Mr. Weingarten, under the Bail Reform Act you are
9
entitled to a continuance of three days, which I guess would
10
take us to Thursday.
11
MR. WEINGARTEN: Right.
12
THE COURT: The other alternative, I guess, if you
13
want to de facto extend that three days is consent to detention
14
without prejudice.
15
MR. WEINGARTEN: We estimated that by Thursday we
16
could get you something in writing and then appear back before
17
you at your convenience.
18
THE COURT: Okay. Do you want to schedule it -- well,
19
I think Thursday's proceedings right now would be in front of
20
Judge Berman unless he wants to send it back to me for bail,
21
but do you want to put this down for detention hearing on
22
Thursday?
23
MR. WEINGARTEN: Can I make one point that I don't
24
want to forget that I think is extremely important?
25
THE COURT: Go ahead.
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=== Page 21 ===
21
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1
MR. WEINGARTEN: The last thing we did today was
2
refuse to answer questions. What we said at Pretrial is heaven
3
forbid we make a mistake, and in terms of assets, we wanted to
4
be precise. So there was no refusal. There was a request for
5
time to supplement. That was accepted. And that's part of the
6
reason we want to sit down and make sure we get our information
7
correct to provide to the court.
8
THE COURT: All right.
9
MR. WEINGARTEN: Can I make one other point?
10
THE COURT: Sure.
11
MR. WEINGARTEN: In terms of the obstruction, I think
12
it is such a significant part of our argument that the conduct
13
at issue is ancient. It is from 2002 to 2005. So obviously if
14
the defendant is a threat to obstruct justice, the court needs
15
to take that into account. The allegations raised -- and I
16
just read them briefly because we just got the government's
17
letter -- relate to negotiations between the feds and the
18
defendant. Back when the Southern District of Florida was
19
attempting to find an appropriate remedy, there were
20
discussions going back and forth: Can we squeeze you into this
21
statute? And it didn't work, and it didn't work because there
22
is no factual basis. That is the reference to the alleged
23
obstruction. Not obstructive acts. Instead, the feds in
24
Florida agreed to the plea to the state offense because there
25
was no appropriate statute that covered conduct that was
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=== Page 22 ===
22
j782epsC kjc
1
proveable. That is the answer to the obstruction issue.
2
THE COURT: All right. So you want to adjourn the
3
detention hearing until Thursday?
4
MR. WEINGARTEN: Yes.
5
THE COURT: All right. Is there any objection to that
6
from the government? I think under the statute he is entitled
7
to three days.
8
MR.
That is, of course, fine, your Honor.
9
I think we would like just a very brief opportunity to
10
respond to some of those arguments so that they don't sort of
11
hang with the court for three days unresponded to.
12
THE COURT: All right. Go ahead.
13
MR.
Just very briefly, your Honor, I
14
think a lot of that discussion was entirely orthogonal to the
15
issues here.
16
But just very briefly, with respect to the charges
17
here, there is simply no force required for underage victims.
18
A grand jury has properly returned an indictment, and these are
19
fact issues that are being presented in large part.
20
Certainly the concept of child prostitution is,
21
frankly, offensive and not recognized in federal law. The idea
22
that children can consent to sex and be prostitutes is beyond
23
the realm of federal law which contemplates trafficking, which
24
is what has been charged here. Mr. Weingarten is free to argue
25
to a jury that trafficking minors was only statutory rape or
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=== Page 23 ===
23
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1
that those victims weren't treated as badly as the parade of
2
horribles he has in mind. But for now the question is whether
3
the defendant's attendance can be assured.
4
And with respect to the nonprosecution agreement --
5
THE COURT: I'm not sure I would refer to something as
6
only statutory rape. The use of the word "only" before
7
"statutory rape" I'm not sure sits well. But go ahead.
8
MR.
And I agree, your Honor.
9
With respect to the actual substance, the Southern
10
District of Florida has represented in public filings that the
11
nonprosecution agreement was limited to the Southern District
12
of Florida, and we can litigate that in a motion to dismiss,
13
but it is simply not relevant here.
14
With respect to the statute of limitations,
15
Mr. Weingarten says that the conduct is old. He did not say
16
that that it is beyond the statute of limitations because it is
17
not.
18
And, finally, it is not the same conduct. Some of the
19
conduct overlaps. Some of the conduct does not. And in
20
particular, one of the two counts of the indictment is
21
predicated exclusively on New York victims.
22
So for all of those reasons, we just ask the court to
23
consider those responses as it awaits the defendant's filings
24
later this week.
25
MR. WEINGARTEN: Can I just make one point to clarify?
SOUTHERN DISTRICT REPORTERS P.C.
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=== Page 24 ===
24
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1
THE COURT: Go ahead.
2
MR. WEINGARTEN: On the statutory rape thing, I had a
3
senior moment. There is no statutory rape because there is no
4
penetration, and that is the answer to that question.
5
THE COURT: All right.
6
We will set this down for a detention hearing on
7
Thursday, July 11, for the continuation of the detention
8
hearing. Thursday, July 11, at 2 p.m.
9
The defendant is detained at least until the
10
continuation of the detention hearing pursuant to 18 United
11
States Code 3142 (f).
12
I have been advised by Judge Berman that he wants to
13
see counsel right after these proceedings. Judge Berman's
14
courtroom is 17B. So counsel and Mr. Epstein should go to 17B.
15
All right. Anything else from the government?
16
MR.
:
Your Honor, ordinarily we would ask
17
to exclude speedy trial time, but I think because we are going
18
directly to Judge Berman, we have no such application.
19
THE COURT: Mr. Weingarten, anything else?
20
MR. WEINGARTEN: No, thank you, your Honor.
21
THE COURT: Mr. Weingarten, anything else?
22
MR. WEINGARTEN: No, your Honor.
23
THE COURT: All right. Thank you all.
24
o0o
25
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EFTA00015629


